1. PURPOSE OF OUR POLICY
(a) Buying and selling motor vehicles; and
(b) The normal day-to-day operations of our business.
2. WHO AND WHAT THIS POLICY APPLIES TO
2.2 We handle Personal Information in our own right and also for and on behalf of our customers and partners.
2.5 If, at any time, an individual provides Personal Information or other information about someone other than himself or herself, the individual warrants that they have that person's consent to provide such information for the purpose specified.
2.6 Our website and services are unavailable to children (persons under the age of 18 years) without their parent or guardian’s consent.
3. THE INFORMATION WE COLLECT
3.1 In the course of business it is necessary for us to collect Personal Information. This information allows us to identify who an individual is for the purposes of our business, share Personal Information when asked of us, contact the individual in the ordinary course of business and transact with the individual. Without limitation, the type of information we may collect is:
(a) Personal Information. We may collect personal details such as an individual’s name, location, date of birth, driver’s licence details, nationality, family details and other information defined as “Personal Information” in the Privacy Act that allows us to identify who the individual is;
(b) Contact Information. We may collect information such as an individual’s email address, telephone & fax number, third-party usernames, residential, business and postal address and other information that allows us to contact the individual;
(c) Financial Information. We may collect financial information related to an individual such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our services;
(d) Statistical Information. We may collect information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes; and
(e) Information an individual sends us. We may collect any personal correspondence that an individual sends us, or that is sent to us by others about the individual’s activities.
3.3 We may also collect non-Personal Information about an individual such as information regarding their computer, network and browser. This may include their IP address. Where non-Personal Information is collected the Australian Privacy Principles do not apply.
4. HOW INFORMATION IS COLLECTED
4.1 Most information will be collected in association with an individual’s use of HelloCars, an enquiry about HelloCars or generally dealing with us. However we may also receive Personal Information from sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners. In particular, information is likely to be collected as follows:
(a) Registrations. When an individual registers with HelloCars whereby they provide Personal Information details in order to buy or sell a motor vehicle with us;
(b) Supply. When an individual supplies us with goods or services;
(c) Contact. When an individual contacts us in any way;
(d) Access. When an individual accesses us physically we may require them to provide us with details for us to permit them such access. When an individual accesses us through the internet we may collect information using cookies (if relevant – an individual can adjust their browser’s setting to accept or reject cookies) or analytical services; and/or
(e) Pixel Tags. Pixel tags enable us to send email messages in a format customers can read and they tell us whether mail has been opened.
4.2 As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their Personal Information is being collected.
4.3 Where we obtain Personal Information without an individual’s knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information, in accordance with the Australian Privacy Principles.
5.1 HelloCars is part of the Google AdWords Remarketing program. Google Remarketing may assign a cookie to track visitors coming and leaving pages or areas of a website. This information is then used to generate Remarketing Lists of visitors that left the site from that particular area or page and may be used to tailor and serve ad content on the Google Display Network that target these groups of users.
6. WHEN PERSONAL INFORMATION IS USED & DISCLOSED
6.1 In general, the primary principle is that we will not use any Personal Information other than for the purpose for which it was collected other than with the individual’s permission. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted.
6.3 If it is necessary for us to disclose an individual’s Personal Information to third parties in a manner compliant with the Australian Privacy Principles in the course of our business, we will inform you that we intend to do so, or have done so, as soon as practical.
6.4 Who do we disclose your information to? We may disclose your personal information and credit-related information to:
(a) Our financiers and finance brokers; where your relationship with us involves the sale or purchase of a vehicle, to any insurers, vehicle dealerships and the private sellers of vehicles in connection with that business (including in connection with the issuing of any invoices);
(b) 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;
(c) suppliers and other third parties with whom we have commercial relationships, for business, marketing, research, and related purposes; and any organisation for any authorised purpose.
(d) We may combine or share any information that we collect from you with information collected by any of our related bodies corporate (within Australia).
6.5 Information is used to enable us to operate our business, especially as it relates to an individual. This may include:
(a) The provision of goods and services between an individual and us;
(b) Verifying an individual’s identity;
(c) Communicating with an individual about:
i. Their relationship with us;
ii. Our goods and services;
iii. Our own marketing and promotions to customers and prospects;
iv. Competitions, surveys and questionnaires;
(d) Investigating any complaints about or made by an individual, or if we have reason to suspect that an individual is in breach of any of our terms and conditions or that an individual is or has been otherwise engaged in any unlawful activity; and/or
(e) As required or permitted by any law (including the Privacy Act).
6.6 There are some circumstances in which we must disclose an individual’s information:
(a) Where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
(b) As required by any law (including the Privacy Act); and/or
(c) In order to sell our business (in that we may need to transfer Personal Information to a new owner).
6.8 We may utilise third-pay service providers (such as Gmail from Google, Inc., SendGrid, Loopit, Zoho and Virtual Yard) to communicate with an individual and to store contact details about an individual.
7. OPTING “IN” OR “OUT”
7.1 An individual may opt to not have us collect their Personal Information. This may prevent us from offering them some or all of our services and may terminate their access to some or all of the services they access with or through us. They will be aware of this when:
(a) Opt In. Where relevant, the individual will have the right to choose to have information collected and/or receive information from us; or
(b) Opt Out. Where relevant, the individual will have the right to choose to exclude himself or herself from some or all collection of information and/or receiving information from us.
7.2 If an individual believes that they have received information from us that they did not opt in or out to receive, they should contact us on the details below.
8. THE SAFETY & SECURITY OF PERSONAL INFORMATION
8.2 We will take all reasonable precautions to protect an individual’s Personal Information from unauthorised access. This includes appropriately securing our physical facilities and electronic networks.
8.3 The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.
8.4 We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s Personal Information to in accordance with this policy or any applicable laws). The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.
8.5 If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.
8.6 We are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information.
9. HOW TO ACCESS AND/OR UPDATE INFORMATION
9.1 Subject to the Australian Privacy Principles, an individual has the right to request from us the Personal Information that we have about them, and we have an obligation to provide them with such information within 28 days of receiving their written request.
9.2 If an individual cannot update its own information, we will correct any errors in the Personal Information we hold about an individual within 7 days of receiving written notice from them about those errors.
9.3 It is an individual’s responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.
9.4 We may charge an individual a reasonable fee for our costs incurred in meeting any of their requests to disclose the Personal Information we hold about them.
10. COMPLAINTS AND DISPUTES
10.1 If you have a dispute regarding an individual’s Personal Information, you must contact us at HelloCars in order for us to investigate the matter further directly between us. HelloCars aim to respond promptly and reasonably to resolve all complaints.
10.2 Upon conclusion of our investigation, if you are not satisfied with the outcome you may escalate the matter to the Office of the Australian Information Commissioner using the details below:
Office of the Australian Information Commissioner
GPO Box 5218 SYDNEY NSW 2001
10.3 If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
11. CONTACTING INDIVIDUALS
11.1 From time to time, we may send an individual important notices, such as changes to our terms, conditions and policies. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications.
12. CONTACTING US
12.1 All correspondence with regards to privacy should be addressed to firstname.lastname@example.org You may contact the Privacy Officer by email in the first instance.
13. ADDITIONS TO THIS POLICY
14. ELECTRONIC COMMUNICATIONS CONSENT
14.1 You consent to Innovate Automotive Pty Ltd (trading as HelloCars) communicating with you electronically via your nominated email address as your address for receiving notices relating to your facility.
14.2 You understand the risks associated with sending or receiving personal information and loan documents via email.
14.3 You should check your nominated email address regularly. Any notice or document we send to you by electronic communications will be deemed to have been received by you.
14.4 You may not receive further paper documents. You are responsible for viewing, printing or saving documents or information you receive from us electronically.
14.5 You can withdraw this consent at any time. If you want to change your email address or withdraw your consent to electronic communication at any time, contact us on 02 8278 9250.