Privacy Policy — Jolly Frog Transfers

Jolly Frog Transfers is operated by John Gentner (sole trader, ABN 59 570 116 144) ("we", "us", "our"). We provide a passenger transport booking service in Queensland and New South Wales through our online booking platform ("JollyDrivers"). To arrange, confirm and bill your trip, we work with Jolly Frog Pty Ltd (ACN 637 828 874, ABN 38 637 828 874) — a separate, related business that provides billing and operational support. We are committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs).

This policy explains what personal information we collect, why, how we handle and protect it, who we share it with (including overseas), and how you can access, correct or complain about it.

Version 1.0 — effective 12 June 2026. This policy is available to you free of charge, in writing, at https://jollydrivers.com.au/privacy; previous versions are available on request.

1. Who we are and how to contact us

Because our trading name ("Jolly Frog Transfers") and our billing partner's name ("Jolly Frog Pty Ltd") are similar, this policy always states the ABN so you can tell which business is meant.

2. Who this policy is about

We handle personal information about several kinds of people, and "you" means whichever applies:

• Passengers / riders — the people travelling.
• Bookers — the person who makes a booking: often the passenger themselves, but sometimes a personal assistant, family member, colleague or other person booking on a passenger's behalf.
• Payers — the person or business responsible for payment (including a business with an ABN where you choose to be invoiced as a business).
• Drivers — the people who carry out trips on our platform (see also the separate driver collection notice).
• Operator staff — people who administer bookings in our operator portal.

If you give us personal information about another person (for example, you book a trip for someone else), you must make sure they know who we are, that you have given us their details, and where they can find this policy.

3. Dealing with us anonymously

You can ask our booking assistant general questions (prices, areas served, vehicle options) without identifying yourself — the booking page does not require an account or sign-in. To actually book a trip we need real details (a name and a way to contact someone about the trip), because it is impracticable to provide a transport service to an anonymous person. Creating an account is optional for booking through the assistant; signing in simply lets you see your trips and manage your details.

4. The personal information we collect

Depending on how you use the service, we may collect:

• Identity and contact details — name, mobile number, email address; if you create an account, your sign-in identity (a Google account identity, or your verified mobile number) and optional profile picture.
• Trip details — pickup, drop-off and any intermediate addresses (and their map coordinates); pickup and return times; flight number and flight times for airport trips; number of passengers and luggage; child-seat and similar options you select; and any notes you provide.
• Booking-origin information — when a booking is taken for you by a driver or operator (for example over the phone), a record of who took it, how and when it arrived, and — if you sent the request by SMS or email — the text of that message.
• Payment and billing information — the payment method you chose (such as cash, card or invoice) and the price; and, if you set up a billing profile for invoicing, your billing name, email, phone, postal address and (for business billing) company name and ABN.
• Account convenience data — addresses you save for quick booking, and how recently/often you used them; trips linked to your account.
• Contact cards kept by your driver — where a driver uses our platform to keep a contact card for their customers, that card (your name, contact details, and the driver's notes relevant to arranging your trips) is stored on our platform.
• Communications and records — booking confirmations and operational messages about your trip, records of the booking messages our system exchanges with our billing partner, and a history of booking changes (who changed what, when).
• Sign-in security data — when you sign in by SMS code, the mobile number, the time, and the IP address the request came from (used to prevent abuse of the sign-in system).

Payment cards. We do not collect, see or store payment card numbers, and our platform does not process card payments. If you pay by card, that happens directly with your driver/operator (for example, a card terminal in the vehicle) or through an invoice issued by Jolly Frog Pty Ltd (ABN 38 637 828 874). Our records hold only the payment method and the amount.

Sensitive information

Some trips can involve sensitive information — for example accessibility, mobility, disability or health-related needs relevant to providing a trip safely. Sensitive information attracts extra protection under the Privacy Act. We only collect it with your express consent (or where otherwise permitted by law), only what is reasonably necessary for the trip, and we share it only with the driver/operator assigned to your trip, to the extent needed to carry it out. See our consent statements.

We do not ask for sensitive information today, and we ask you not to put health or accessibility details in free-text notes — if you have an accessibility need, contact us at privacy@jollyfrog.net.au (or use the accessibility option in the booking flow when available) so we can record it properly, with your consent.

5. How we collect personal information

• Directly from you — when you book through our booking assistant or forms, create or update an account, set up a billing profile, or communicate with us.
• From the person who books on your behalf. If someone books a trip for you (a family member, assistant or colleague), your details reach us from them, and you may not have dealt with us directly at that point. Our collection notice and this policy explain what happens to your information, and we ask the booker to make sure you know.
• From the driver or operator who takes your request. If you phone, SMS or email a request, the driver/operator enters your details into our platform, including (for SMS/email requests) the text of your message.
• Automatically as part of providing the service — route distance and time estimates for your trip, records of booking changes, and the sign-in security data described above.

We collect personal information by lawful and fair means, and only what is reasonably necessary for the purposes below.

6. Why we collect, hold and use personal information

We use personal information to:

• arrange, provide, confirm and manage your transport booking;
• assign and coordinate a driver and vehicle to carry out the trip;
• communicate with you about your booking (confirmations and operational updates);
• pass booking details to Jolly Frog Pty Ltd (ABN 38 637 828 874) so your trip can be confirmed, scheduled, invoiced and recorded — see section 8;
• provide account features you choose to use — your trip history, saved addresses, billing profiles, and rebooking a past trip;
• meet safety and quality needs you've told us about (for example, fitting the right child seat);
• keep records required of a passenger transport service, and meet our legal obligations; and
• where you have separately opted in, send you marketing (see section 10 — we currently send none).

6.1 Our AI booking assistant and other automated processing

• AI booking assistant. Our booking chat is powered by an external AI service provider, Anthropic (United States). What you type in the booking conversation — and the booking details the assistant needs to help you (which can include stored contact details when a driver books for an existing customer) — is processed by Anthropic on our behalf to run the conversation. The assistant helps take your booking; it does not decide whether your booking is accepted, what you pay, or who drives you — those are done by people. Anthropic is an overseas recipient — see section 11.
• Linking trips to your account. If you have an account with a verified mobile number, we automatically link bookings that carry that number to your account, so you can see your trips.
• Trip record completion. If a booking is recorded after the trip already happened, our system fills in estimated stage times for the record. This is bookkeeping; it does not change what you pay.

We do not use automated pricing, automated acceptance/decline of bookings, or automated driver assignment. Any automated processing above can be reviewed by a person — if you believe it has affected you adversely, contact privacy@jollyfrog.net.au.

7. Who we share personal information with

We share only what each recipient needs for their role:

• The driver (and their operator) assigned to your trip — the trip details needed to find you and carry out the trip: passenger name, contact number, pickup/drop-off and stops, times, flight details, luggage and child-seat needs, and any accessibility detail you have expressly consented to share.
• Jolly Frog Pty Ltd (ABN 38 637 828 874) — our billing and operations partner, a separate business. We send it your booking details (booker and passenger name and contact details, trip addresses and times, flight details, options and notes, price and payment method, and — where a driver took your request by SMS/email — the text of that request) so it can confirm, schedule, invoice and keep records of the trip; it sends booking status and corrections back to us. It handles your information under its own privacy policy (available from privacy@jollyfrog.net.au), including its own providers (such as Xero for accounting and Google for scheduling).
• Anthropic (AI booking assistant) — the content of your booking conversation, as described in section 6.1. Overseas recipient — see section 11.
• Google — (a) if you sign in with Google, Google authenticates you and we receive your account identity (name, email, picture); (b) when you enter addresses, they are checked against Google's Maps/Places services to find, validate and route them. Overseas recipient — see section 11.
• SMSGlobal (SMS provider, Australian-based) — your mobile number and the text of sign-in code messages we send you.
• Our email / mail-hosting provider (Hosting Australia, Australian-based) — hosts the mailboxes through which our platform exchanges booking messages with Jolly Frog Pty Ltd; because those messages carry booking details, copies exist in those mailboxes.
• Our hosting infrastructure — our records are stored on infrastructure located in Australia.
• A driver you choose to share your details with. If you use "My Drivers" to share your live contact details with a driver you travel with, that driver's contact card for you stays linked to your account until you unlink it. This sharing is entirely your choice and you can end it at any time in your account.
• Professional advisers, and in connection with a business sale or restructure — under confidentiality.
• Authorities — see section 9.

We do not sell, rent or trade your personal information, and we do not disclose it for any other organisation's marketing.

8. Our relationship with Jolly Frog Pty Ltd

You book with Jolly Frog Transfers (John Gentner, ABN 59 570 116 144). Billing, scheduling and record-keeping support is provided by Jolly Frog Pty Ltd (ABN 38 637 828 874). They are separate businesses under common ownership, and passing your booking details between them is a disclosure between businesses that both treat as governed by the Privacy Act. Each business has its own privacy policy; access, correction and complaint requests sent to the shared privacy contact (privacy@jollyfrog.net.au) reach both.

9. Disclosure to courts, regulators and law enforcement

We may disclose personal information where required or authorised by law — for example a subpoena, warrant, court order, or a statutory notice from a passenger transport regulator (such as the Queensland Department of Transport and Main Roads or the NSW Point to Point Transport Commissioner). We may also disclose where we reasonably believe it is reasonably necessary for an enforcement body's functions — for example assisting police with a safety incident. Where we make a disclosure of that second kind, we make a written record of it, as the law requires.

We have no automated reporting to government bodies; any such disclosure is assessed case by case.

10. Direct marketing

We do not currently send any marketing. If we ever introduce it, we will only send marketing to people who have separately opted in; every message will identify us and include a free, easy unsubscribe (reply STOP to any marketing SMS); and we will keep a record of opt-outs so they keep being honoured. Marketing is never a condition of booking, and opting out never affects the operational messages needed to provide a trip you've booked.

11. Sending information overseas (cross-border disclosure)

Some providers we use store or process personal information outside Australia:

• Anthropic (AI booking assistant) — United States.
• Google (sign-in and address/maps services) — the United States and other countries where Google operates.

Our own hosting infrastructure is located in Australia and is not an overseas disclosure.

Before disclosing personal information to an overseas recipient on this basis, we take reasonable steps to ensure it is handled consistently with the APPs — for example, relying on the provider's contractual data-protection commitments and assessing their privacy and security practices — and we remain accountable to you under the Privacy Act for how these providers handle your information.

Our SMS provider (SMSGlobal) and mail host (Hosting Australia) are Australian-based; messages may transit international carriers in delivery, which is a technical necessity rather than a disclosure to a foreign processor.

12. How long we keep personal information

We keep personal information only as long as we need it for the purposes above, or as long as the law requires records to be kept (including passenger-transport and tax record-keeping obligations that apply to the businesses providing and billing your trip).

As a guide: booking and trip information — including the content of booking messages about your trip — is kept for at least 2 years, consistent with passenger-transport record-keeping requirements, after which we remove message content and unneeded personal details from our active systems. Billing records are kept by Jolly Frog Pty Ltd under its own policy (7 years, as company and tax law requires). If you opt out of any message type, we keep your number/email on our do-not-contact list for as long as we send that kind of message — keeping that record is how the opt-out keeps being honoured. Copies of deleted information may persist for a further limited period in routine security backups before expiring on a rolling basis.

When we no longer need personal information and are not required to keep it, we take reasonable steps to destroy or de-identify it.

13. How we keep personal information secure

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure — including role-based access to the driver, operator and rider portals; verified sign-in (Google or SMS code, with codes stored hashed and rate-limited); encrypted connections to our service providers; and limiting who can see what (for example, a driver sees their own customers and trips, not other drivers'). No system is perfectly secure, but we work to protect your information and to respond promptly if something goes wrong, including notifying you and the Office of the Australian Information Commissioner (OAIC) where an eligible data breach occurs.

14. Accessing and correcting your information

If you have an account, you can see and update much of your information yourself — your profile, your trips, your saved addresses, your billing profiles, and the drivers you've chosen to share your details with. For anything else (including information collected when someone booked for you, or if you don't have an account), contact us at privacy@jollyfrog.net.au. You can ask for access to the personal information we hold about you and for correction if it is inaccurate, out of date, incomplete, irrelevant or misleading. We will respond within 30 days, or let you know if a complex request needs longer. In most cases access is free; we will tell you in advance if a cost applies. If we cannot give access or make a correction, we will explain why and how you can have the matter reviewed.

15. How to make a privacy complaint

Contact us first (privacy@jollyfrog.net.au · 0412 207 533) so we can try to resolve it; we will acknowledge your complaint and respond within a reasonable time. If you are not satisfied, you can complain to the Office of the Australian Information Commissioner (OAIC): oaic.gov.au · 1300 363 992.

16. Changes to this policy

We may update this policy from time to time. The current version, with its effective date, is always available free of charge at https://jollydrivers.com.au/privacy, and we keep prior versions. If we make a material change to how we handle your personal information, we will take reasonable steps to tell you — and where a change introduces a new purpose, recipient or overseas destination that relies on your consent, we will ask for your consent again rather than assume the earlier one carries over.

This policy is maintained as version-controlled text; prior versions are available on request.