Skip to main content

Wi-Fi Privacy Policy

Privacy Policy

Flixbus Australia Pty Ltd ACN 686 837 301 (Flix Australia) understands the importance of protecting the privacy of an individual’s personal information. This policy sets out how Flix Australia aims to protect the privacy of your personal information when using OnBoard Wi-Fi services, your rights in relation to your personal information managed by Flix Australia, and the way Flix Australia collects, holds, uses and discloses your personal information. In handling your personal information, Flix Australia complies with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs) in the Privacy Act, and all other relevant Australian privacy laws.

1. What kind of personal information does Flix Australia collect?

(a) Personal information is information or an opinion about an identified, or reasonably identifiable, individual. 

(b) When you access and use Flix Australia’s OnBoard Wi-Fi service, Flix Australia may collect the following types of (personal) information:

  • MAC address of the access device used
  • Assigned connection number
  • IP address of the device
  • Connection start and end times, and duration of use
  • Data volume transferred (including average packet size)
  • Technical details of connection setup/termination
  • Location/name of the access point used
  • Hardware type and manufacturer of the device
  • Operating system identification data
  • Browser identification data (including language and time zone)

(c) Provision of (personal) information is voluntary, but some Wi-Fi services may be limited if you do not provide the required information.

2. How does Flix Australia collect personal information?

Flix Australia collects your personal information directly when you use the OnBoard Wi-Fi system. Information is generated through the technical connection and may also be provided by third-party service providers who operate or support the Wi-Fi infrastructure.

3.  Why does Flix Australia need your personal information?

(a) Flix Australia collects, holds, uses and discloses your personal information where it is reasonably necessary for the following purposes:

  • To provide Wi-Fi connectivity on board
  • To verify identity of devices connected to the network
  • To monitor, maintain and improve service quality
  • To compile anonymous statistics and improve travel experience
  • To meet legal obligations or respond to lawful requests

(b) Flix Australia may also use or disclose your personal information for purposes related to the above purposes and for which you would reasonably expect Flix Australia to use or disclose your personal information, where you have consented to the use or disclosure, or where the use or disclosure is otherwise in accordance with law.

(c) Where personal information is used or disclosed, Flix Australia takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is used or disclosed.  You are under no obligation to provide your personal information to Flix Australia.  However, without certain personal information from you, Flix Australia may not be able to provide its products and/or services to you or otherwise engage with you in relation to any queries you have in relation to Flix Australia’s products and/or services.

(d) If Flix Australia receives personal information about you that it has not requested and it determines that the personal information received is not reasonably necessary for it to provide its products and/or services to you, or for its other functions as described above, Flix Australia will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.

4.  To whom does Flix Australia disclose your personal information?

(a) Flix Australia may disclose your personal information for the purposes for which Flix Australia collects it.  That is, generally, Flix Australia will only disclose your personal information for a purpose set out at paragraph 3 above.  This may include disclosing your personal information to:

  • Third-party (IT) providers (e.g. RebelRoam, Peplink)
  • Flix SE and other group companies (which may be located overseas)
  • Regulatory bodies and agencies when required by law

(b) Flix Australia’s disclosures of your personal information to the above third parties will be on a confidential basis or otherwise in accordance with law.  Flix Australia may also disclose your personal information with your consent or if disclosure is required or authorised by law.

5. Overseas disclosure

Personal information collected through OnBoard Wi-Fi may be transferred overseas, including to Flix SE in Germany and other Flix group companies. Before disclosing any personal information overseas, Flix Australia takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme, unless you consent to the overseas disclosure or it is otherwise required or permitted by law.

6. Can you access and correct personal information that Flix Australia holds about you?

(a) Flix Australia takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading.  

(b) Under the Privacy Act, you may seek access to and correction of your personal information that is collected and held by Flix Australia.  If at any time you would like to access or correct the personal information that Flix Australia holds about you, or you would like more information on Flix Australia’s approach to privacy, please contact Flix Australia’s privacy department on the details set out in paragraph 8 below.

(c) Where Flix Australia outsources any of its functions relating to the provision of its products and/or services to you, any request for access to or correction of the personal information held by that service provider or other third party may need to be made to the relevant service provider or third party. 

(d) Flix Australia will grant access to the extent required or authorised by the Privacy Act and take steps reasonable in the circumstances to correct personal information it holds about you where necessary and appropriate.  

(e) To obtain access to your personal information:

a.  you will have to provide proof of your identity to enable Flix Australia to confirm that the personal information to which you seek access is about you and to ensure that the privacy of others is protected;
b.  Flix Australia requests that you be reasonably specific about the personal information you require; and
c.  Flix Australia may charge you a reasonable administration fee, which reflects the cost to Flix Australia, for providing access in accordance with your request.

(f) Flix Australia will endeavour to respond to your request to access and/or correct your personal information within 30 days from receipt of your request.

7. Security of your personal information

(a) Flix Australia takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. 

(b) Flix Australia holds personal information in both hard copy and electronic forms in secure servers or in storage located in secure environments and access is restricted to authorised personnel only.  Flix Australia’s employees are required to maintain the confidentiality of any personal information held by Flix Australia.

(c) Flix Australia will destroy or de-identify personal information in circumstances where it is no longer required, unless Flix Australia is otherwise required or authorised by law to retain the information.

8. How to contact us

For further information, to request access to or correction of your personal information, or to make a privacy complaint, please contact:

Flixbus Australia Pyt Ltd 
Level 18, 347 Kent Street 
Sydney, NSW, 2000 Australia 
e-mail: data.protection.au@cs.flixbus.com

9. Privacy complaints

(a) Please direct all privacy complaints to Flix Australia’s privacy department in writing using the contact details contained under paragraph 8. At all times, privacy complaints:

a.  will be treated seriously;
b.  will be dealt with promptly; 
c.  will be dealt with in a confidential manner; and
d.  will not affect your existing obligations to Flix Australia or the commercial arrangements between you and Flix Australia. 

(b) In the event you are dissatisfied with Flix Australia’s response to your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.

10. Review of this policy

This policy may be reviewed and updated from time to time.  Where Flix Australia updates this policy, Flix Australia will make the updated policy available.