Carconnect Pty Ltd ACN 104 742 449 (referred to below as "carconnect", "we" and "us") owns and operates the websites located at www.carconnect.com.au.
2. What types of information are covered by this policy?
This policy sets out how we manage your "personal information".
When used in this policy, the term "personal information" has the meaning given to it in the Privacy Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
3. What personal information do we collect and hold?
We may collect the following types of personal information about you:
- mailing or street address;
- email address;
- telephone number;
- facsimile number;
- age or birth date;
- any additional information relating to you that you provide to us through our website; and
- any other information that you provide to us in person, including over the telephone, by email, at our offices or during your dealings with our representatives.
We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.
4. How do we collect your personal information?
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:
- through your access and use of our website;
- via e-mail, in person, by mail or by fax; or
- over the telephone or during conversations between you and our representatives.
5. What happens if we can't collect your personal information?
If you do not provide us with the personal information described above, some or all of the following may happen:
- we may not be able to provide you with vehicle broking services or any other products or services that we offer from time to time;
- we may not be able to provide you with information about vehicles that you are interested in or any other products or services that we offer from time to time, including information about special promotions; or
- we may be unable to tailor the content of our website to your preferences and your experience of our website may not be as enjoyable or useful.
6. For what purpose do we collect, hold, use and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and to provide best possible quality of customer service to you. We collect, hold, use and disclose your personal information for the following purposes:
- to provide you with vehicle procurement services and other products and services that we may offer from time to time;
- to provide you with news, information or advice about our vehicle procurement services and any other existing and new products and services that we may offer from time to time;
- to communicate with you including by email, mail or telephone;
- to personalise and customise your experience with us, including your experience using our website;
- to share your information within Stratton Finance Pty Ltd (including with our related bodies corporate and franchisees), so that our other divisions and businesses may also contact you or offer you complementary or other products and services;
- to answer enquiries and provide information or advice about vehicles that you are interested in and any other existing and new products and services that we may offer from time to time;
- to provide you with access to protected areas of our website;
- to assess the performance of our website and to improve the operation of our website;
- to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
- for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of us and our related bodies corporate, contractors or service providers;
- to assist the performance of, and to improve, any marketing and advertising campaigns that we conduct;
- to provide your updated personal information to our related bodies corporate, contractors or service providers;
- to update our records and keep your contact details up to date;
- to process and respond to any complaint made by you; and
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in cooperation with any governmental authority.
Your personal information will not be shared, sold, rented or disclosed other than as described in this policy.
7. Our Website
7.1 Application of this policy
This policy also applies to any websites that we operate from time to time. This policy will cover any personal information you provide to us using any of our websites.
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
8. Who do we disclose your personal information to?
We may disclose your personal information to:
- our related bodies corporate, including (without limitation) Stratton Finance Pty Ltd (ACN 070 636 903);
- to any vehicle dealerships and the private sellers of vehicles in connection with the sale or purchase of a vehicle (including in connection with the issuing of any invoices);
- to any financiers or insurers connected with the sale or purchase of a vehicle;
- our employees, related bodies corporate, contractors or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
- suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and
- any organisation for any authorised purpose with your express consent.
We may combine or share any information that we collect from you with information collected by any of our related bodies corporate (within Australia).
9. Direct marketing materials
We may send you direct marketing communications and information about our products and services (or those of our related bodies corporate) that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. If we do commence sending any direct marketing to you, you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.
10. Do we disclose your personal information to anyone outside of Australia?
We may disclose personal information to our related bodies corporate and our third party suppliers and service providers located overseas for some of the purposes listed above.
We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your information.
We may disclose your personal information to entities located outside of Australia, including to our data hosting providers and to other IT service providers, some of whom are located in the United States of America.
11. Security and data quality
We take reasonable steps to ensure that the personal information that we collect, use and disclose about you is accurate, complete and up-to-date and, in relation to the purpose of our use or disclosure, relevant. Personal information is destroyed or de-identified when no longer needed or where we are no longer required by law to retain it (whichever is the later).
We store information in different ways in both hardcopy and electronic form (including in various databases). We have implemented controls around technology and our organisational processes to assist us in protecting your information from misuse, interference and loss and from unauthorised access, modification or disclosure. This includes having in place confidentiality requirements for employees and contractors, as well as implementing document storage security policies, systems and site access restrictions.
12. How can you access and correct your personal information
You may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a reasonable fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your personal information.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that any personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.
13. What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.
We have a detailed internal dispute resolution policy, which will apply to investigating and dealing with any privacy breaches. Please contact us (using the details below) to obtain a copy of this policy.
We will treat your complaint confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
If you are not satisfied with our handling of your complaint or our proposed resolution, you have a right to lodge a further complaint with the Office of the Australian Information Commissioner (for more information, please see http://www.oaic.gov.au). The Office of the Australian Information Commissioner can provide you with further information about the next steps in its complaints process.
14. Contacting us
If you have any questions about this policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Compliance Officer using the details set out below. We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
Please contact our Compliance Officer at:
PO Box 5012
South Melbourne, VIC, 3205
Telelphone: 1300 STRATTON (1300 787 288)
This policy was last updated on 17th July 2020.