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At Zupps we
are committed to providing you with the highest level of customer
service and we understand the importance of respecting and
safeguarding the privacy of our customers and visitors to
our website.
Automotive Holdings Pty
Ltd and its Related Entities (as that term is defined
in the Corporations Act 2001) are referred to as the
“Zupps Group” in this document.
The Zupps Group is bound by the National Privacy Principles
under the Privacy Act 1988 and this Privacy Policy applies
to all companies across the Zupps Group.
A copy of the National Privacy Principles is available for
your perusal at our premises, or you may obtain a copy from
the Office of the Federal Privacy Commissioner.
The Privacy Act 1988 regulates the way in which personal information
about customers can be used by businesses, from initial collection
to use and disclosure, data quality & security, accessibility
and disposal. Wherever practical, an individual has the right
to interact with the Zupps Group and its staff without providing
personal information.
This Privacy Policy does not apply to acts and practices which
relate directly to the employee records of our current and
former employees.
This Privacy Policy is intended to provide a general overview
of our policies and our commitment to you in respect of the
handling of your personal information.
Your Personal Information
Personal information as defined by the Privacy Act
1988 is any information or opinion about you that is capable
of identifying you.
1. Collection
How your personal information may be collected
The Zupps Group will endeavour to collect your personal
information directly from you whenever possible, and will
limit the personal information we collect to that which is
necessary for our functions or activities. We may also acquire
lists from other sources, both from other companies and from
other public documents.
We may collect personal information from you in a variety
of ways including, without limitation:
- Through the completion of vehicle purchase contracts;
- Through questionnaires;
- Through Zuplink membership application forms;
- Through the Zupps website via vehicle enquiry forms, finance
enquiry forms or Zuplink membership application forms;
- Over the telephone; and
- During person-to-person contact.
There may be some instances where we collect personal information
about you from other sources. Some examples include, but are
not limited to:
- A referral from an existing customer;
- Confirmation of your details of employment, income, and
other financial details from your employer or other third
party when assessing applications for finance; and
- Credit reference checks when assessing applications for
finance.
The collection of personal information will only:
- Be collected by lawful and fair means and not in an unreasonably
intrusive way;
- Be used for a lawful purpose; and
- Be collected with your consent.
When collecting personal information, we will endeavour to
make you aware of the purposes for which the information is
being collected by us, the organisations to which we would
usually disclose your information, and any consequences for
you if you fail to provide any information that is requested
by us.
As a general rule we do not collect sensitive information.
However, if we do, it will usually be for the purposes of
providing our goods or services and if the law requires us
to, we will seek your consent to collect it.
Types of personal information collected
The personal information we hold about our customers
and other individuals (including information we obtain from
third parties) may include your:
- Name;
- Date of birth;
- Current and previous address;
- Home, business and mobile telephone numbers;
- Home and/or business facsimile numbers;
- E-mail address/s;
- Driver’s licence number;
- Occupation;
- Financial information about personal or business finances;
- Credit reports;
- Banking details including account numbers;
- Insurance and finance details; and
- Motor vehicle (and related product) details - vehicles
owned, traded-in or purchased by you, registration, modifications,
vehicle identification numbers (VIN), details of purchase,
courtesy car loan/s, warranty and repair histories
If you choose not to provide personal information, we may
not be able to provide you with the service you require, or
the level of service on which we pride ourselves.
2. Use and Disclosure
We will generally only use or disclose your
personal information for the primary purpose of collection,
for a secondary purpose which is related to the primary purpose
and which we consider will be within your reasonable expectations
or where we are required or permitted to do so by law. Otherwise,
we will seek your consent prior to using or disclosing your
personal information for another purpose, unless we are required
or permitted by law to do so without seeking your permission.
We will not seek a broader consent than is necessary for the
circumstances.
Information will only be disclosed for a secondary purpose
where the secondary purpose is related to the primary purpose
and the individual would reasonably expect the organisation
to use or disclose the information for the secondary purpose.
We will not provide your personal information to any other
organisation for marketing purposes without your consent and
will not sell or trade your personal information to non-related
companies or persons.
Further information about our use and disclosure of personal
information is set out below.
How your personal information may be used
Your personal information may be used to:
- Consider an application or proposal made by you to us;
- Process a sales contract or any other transaction between
you and us;
- Evaluate and monitor credit worthiness;
- Process receipts and payments and send invoices;
- Respond to enquiries about applications, accounts or services;
- Complete an application for the provision of Financing
facilities relating to the purchase of a New or Used motor
vehicle. The information requested is the minimum required
by the finance providers;
- Complete an application for the provision of Insurance
cover;
- Provide after-sales service for your vehicle;
- Perform our internal administration and operations including:
accounting, risk management, record keeping, archiving,
systems development and testing;
- Conduct credit scoring;
- Offer you new products and services that we believe may
interest you;
- Conduct market research in relation to the products and
services referred to in the preceding paragraphs;
- Consider information concerning prospective employees
and make offers of employment; and
- Meet legal and regulatory requirements.
Disclosure of your personal information
For the purposes set out above we may disclose your
personal information to organisations outside the Zupps Group.
The organisations to which we disclose information include:
- Outsourced service providers who manage the services we
provide to you including:
- Mailing systems;
- Debt recovery functions; or
- Information technology services.
- Your representatives (eg: your authorised representatives
or legal advisors);
- Insurance companies, their subsidiaries or agents for
the purpose of processing insurance applications;
- Finance providers in connection with an application for
finance for the purchase of a new or used motor
vehicle;
- Credit-reporting and fraud checking agencies;
- Credit providers for credit related purposes such as credit-worthiness,
credit rating, credit provision and financing;
- Our professional advisors, including our accountants,
auditors and lawyers;
- Government and regulatory authorities and other organisations,
as required or authorised by law;
- Organisations involved in:
- A transfer / sale of all or part of our assets or
business (including accounts and trade receivables);
and
- Managing our corporate risk and funding functions
(eg: securitisation)
- Car manufacturers, retailers, dealers and insurers for
purposes of maintaining your car, customer satisfaction
measurement, marketing, product development and warranty
maintenance;
- Third parties who provide services relevant to our customers
such as:
- Mechanics;
- Insurers;
- Financiers; and
- Other third parties.
- Potential investors, joint venturers or acquirers, and
- Other companies within the Zupps Group
We enter into contractual agreements with these organisations
to ensure that information we disclose is used only for the
limited purposes for which we have provided it.
3. Data quality, security
& storage
We store your personal information securely and take
all reasonable precautions to ensure that the personal information
we collect, use and disclose is accurate, complete and up-to-date.
However, the accuracy of the information depends to a large
extent on the information you provide. That’s why we
recommend that you:
- Let us know if there are any errors in your personal
information; and
- Keep us up-to-date with changes to personal information
such as your name and address.
The Zupps Group strives to ensure the security, integrity
and privacy of our customers’ personally identifiable
information. We use a variety of physical and electronic security
measures including restricting physical access to our offices,
passwords, firewalls, virus protection and secure databases
to keep personal information secure from misuse, loss or unauthorised
access, use, modification or disclosure.
We will retain information for as long as it is necessary
to service your account or to continue to provide products
and services you have requested or purchased from us. We will
retain information for a reasonable period if you cease to
be our customer unless the law requires us to keep it for
longer.
We will endeavour to destroy or permanently de-identify your
personal information as soon as it is no longer required by
us (and this is permitted by law).
When using our website, you should be aware that no data
transmission over the Internet can be guaranteed as totally
secure. Although we strive to protect such information, we
do not warrant the security of any information that you transmit
to us over the Internet and you do so at your own risk.
4. Collection, use, disclosure
& storage of non-personally identifiable information –
clickstream data
The types of information we keep on record will depend
on the type of form or survey you complete or the product
or service you request. Generally, we keep a record of the
following types of information:
When you visit our website:
The Zupps Group collects non-personally identifiable
information from each site visitor. When visiting our website
(www.zupps.com.au), a record of your visit is logged. By using
our website, you give the Zupps Group permission to collect
information about the pages served to you as an anonymous
user for the purpose of calculating aggregate site statistics.
The following clickstream data is recorded and is used by
the Zupps Group for statistical purposes:
- Your server address;
- Your top level domain name (eg: .com, .gov, .au, etc);
- The type of browser you are using (eg: Internet Explorer,
Netscape, etc);
- Your operating system (eg: Windows, Mac, etc);
- The date and time of the visit to the site;
- The pages accessed and any documents downloaded; and
- The Internet address of the website from which you
linked directly to our site.
This information is used to monitor general usage trends
of the website. No attempt will be made to identify users
with their browsing activities, except in the unlikely event
of an investigation, where the law enforcement agency may
warrant to inspect the Internet log files. All information
collected from the Zupps website is stored on our web server,
but is not publicly accessible from the website.
Cookies
A cookie is a piece of data that a website can send
to your browser, which may then be stored on your computer
as an anonymous tag that identifies your computer but not
you. The Zupps website uses cookies to better serve you when
you return to the website. You can set your browser to notify
you before you receive a cookie, giving you the chance to
decide whether to accept it. You can also set your browser
to turn off cookies. If you do so, however, some pages in
the site may not work properly.
Links to other sites
The Zupps website may contain links to other websites
maintained by other organisations. We have no affiliation
with those websites, do not endorse any material on those
websites and do not provide any warranty, or assume any responsibility,
regarding the quality, accuracy, source, merchantability,
fitness for purpose or any other aspect of the material on
those websites. The Zupps Group is not responsible for the
privacy practices or the content of such websites.
The information contained in the Zupps website is subject
to change without notice, so please check back periodically.
The Zupps website is intended as general information only
and is not complete or definitive. The Zupps Group is not
liable and does not take any responsibility whatsoever for
reliance on such information.
When you e-mail us:
Should you send us an e-mail containing personal
information we will ensure that the confidentiality of that
information is maintained. The content of e-mails is sometimes
monitored by our Internet Host for maintenance and fault detection
purposes. We may also monitor e-mails for legal compliance
purposes. E-mails are also sent to the relevant department
within the Zupps Group when they relate to product enquiries
or complaints. When you email us:
- We will record your email address;
- We will only use your email address for the purpose for
which you provided it;
- It will not be added to a mailing list unless you have
specifically requested this;
- We will not use your email address for any other purpose;
and
- We will not disclose your email address without your consent.
When you join Zuplink online at www.zupps.com.au
When you join our customer rewards program (Zuplink)
online, we require certain information. We need:
- Your first name, last name, postal address and contact
telephone numbers so that we can send you a membership information
kit and membership card
- Your e-mail address so that we can send you e-mail notices;
- A user name and password so that you can log on to the
members only area of the website; and
- A confirmation password to verify that you have correctly
typed your password;
When you submit a new or used vehicle enquiry, finance
enquiry, parts enquiry or book a service online
When you enquire about a Zupps product or service, you will
be asked to submit certain information. This information may
be accessed and reviewed by authorised Zupps staff and may
in addition be passed onto a third party organisation so that
they can assist with your enquiry. This process is designed
to assist you in obtaining products or services to suit your
requirements. If you do not wish for your information to be
used in this way, please do not complete our online enquiry
or service booking forms.
Where you choose to send us a completed electronic form
that includes your personal details, we do collect personally
identifiable information such as name, address, telephone
numbers and e-mail address. The information collected by e-mail
or electronic forms will be used only for the purpose for
which you provided it, and we will not disclose it without
your consent, except where authorised or required by law.
5. Marketing
From time to time we may send marketing materials
to our customers and other people who have provided us with
personal information about the products and services we provide.
You have the right to request that we do not provide you with
such material or information, and should you not wish to receive
it, simply contact the Zupps Marketing Department on (07)
3877 0123 and advise us accordingly. Once we have been informed
that you no longer wish to receive information about or products
and services, you will not be sent anything further. You may,
at any stage, opt to change your mind about receiving such
information.
If you do not wish to receive marketing materials from the
Zupps Group, we will note your request and respect your wish
not to receive any marketing materials.
If you choose not to receive any marketing materials from
the Zupps Group, you may miss ut on special product and service
offerings and opportunities.
Electronic Communications
The Spam Act 2003 regulates the way in which Australian
businesses can communicate electronically using e-mail, short
message service (SMS), multimedia message service (MMS) and
instant messaging (iM). In compliance with the Spam Act 2003,
the Zupps Group will not send any unsolicited commercial electronic
messages.
Consent: Messages will only be sent to an address when it
is known that the person responsible for that address has
consented to receive it.
Identify: All e-mail communication will be clearly identifiable
as having been sent by the Zupps Group.
Unsubscribe: An unsubscribe function will be included in
every e-mail newsletter communication from the Zupps Group
so you can opt out from this service at any time.
When you join our email notification service
When completing online forms as registration to receive
news and special offers from the Zupps Group, you are consenting
to receive news and special offers via e-mail. You will be
contacted by the Zupps Group via e-mail with newsletters and
details of special offers as per your request.
SMS Alerts
The Zupps Group may send you an SMS (short message
service) to advertise products and services that we believe
will suit your current requirements. The mobile phone numbers
to which we send messages are obtained from our customer database
and publicly available sources.
6. Access and Correction
You can access your personal information
You may contact us to request access to the personal information
about you that we hold. We may refuse to allow you to access
your personal information if we are legally required or entitled
to do so. If we deny you access we will tell you why. You
may be required to put your request in writing for security
reasons.
The Zupps Group reserves the right to charge a fee for searching
for and providing access to your information. We will advise
the amount of the fee payable (if any) once we have assessed
your application for access. Any request for access to personal
information will not incur a fee. If you lodge a request for
access, we may provide you with access to your personal information
in any of a number of ways (including, for example, supplying
you with a copy of your personal information, or providing
you with the opportunity to view your personal information).
If you can establish that any personal information we hold
about you is not accurate, complete and up-to-date, we will
take reasonable steps to correct it so that it is accurate,
complete and up-to-date, where it is appropriate to do so.
If we are unable to agree that the personal information we
hold about you is accurate, complete and up-to-date, or if
it is inappropriate for records to be amended, you may ask
us to place with the information a statement claiming that
you believe the particular information is not accurate, complete
and up-to-date.
To obtain access you will have to provide proof of your identity.
This is necessary so that the Zupps Group can ensure that
your personal information is not disclosed to any other person.
Please contact us if you:
- Wish to have access to the personal information that we
hold about you;
- Consider that the personal information that we hold about
you is not accurate, complete or up to date and wish to
make amendments to our records;
- Want to remove any of the personal information which you
do not wish us to retain;
- Want to be removed from our mailing list/s; or
- Require further information on our personal information
handling practices.
Complaints and Disputes
If you have reason to believe that any Zupps Group
affiliate or department has breached the Privacy Policies
outlined in this document, we urge you to raise this with
the Zupps Privacy Officer. We will investigate all complaints
and respond to you within 14 days. If we find a complaint
justified, we will promptly resolve it. If necessary, we will
change policies and procedures to maintain our high standards
of performance, service and customer care.
7. Identifiers
The Zupps Group will not use identifiers assigned
by government agencies as its own identifier. An ABN is not
an identifier.
8. Transfer to Foreign
Countries
Some of our uses and disclosure of your personal
information may involve us transferring your personal information
to foreign countries (for example if you purchase a car which
is manufactured by a manufacturer based in a foreign country).
9. Our employees and
training
We will provide training and communications programs
designed to educate employees about the management of personal
information relevant to their respective roles and responsibilities
and of the meaning and requirements of our Privacy Policy.
Only properly authorised people are permitted to see or use
personal information held by the Zupps Group. Employees who
intentionally or negligently breach the Privacy Policy will
be subject to disciplinary action.
10. Changes to the Zupps
Privacy Policy
We reserve the right to amend this Privacy Policy
at any time, at our discretion and without notice. From time
to time we may use customer information for new, unanticipated
uses not previously disclosed in our Privacy Policy. If the
requirements of the National Privacy Principles change in
the future, we will change our Privacy Policy as necessary
to meet those requirements. You may obtain a copy of the current
version of our Privacy Policy by contacting us.
11. How to contact us
If you have any questions in relation to your privacy,
or if you wish to exercise your rights of access and correction,
please contact us via any of the following:
Phone: (07) 3877 0011 between 8:30am and
5:00pm, Monday to Friday
Write to: The Zupps Privacy Officer, C/- Zupps Corporate,
PO Box 121, Mt Gravatt, Qld, 4122
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