The Suttons Motors Group Respects your Privacy
Our policy for dealing with any of your personal information held by us is explained below.
Collection of personal information
The type of personal information we collect depends on the nature of your dealings with us and the reason for collecting it.
We may collect personal information if you:
purchase a new or used motor vehicle from us;
complete and submit a form through our website;
apply for finance through us;
are one of our suppliers;
are a subscriber to our mailing list or newsletter; or
submit a job application.
The types of personal information that we may collect and hold for our activities includes, without limitation:
an individual's name;
date of birth;
physical or postal addresses;
telephone and fax numbers;
driver's licence details;
credit card details or bank account information;
salary and personal finances (for loan applications);
health information (for life or disability insurance);
details of current or previous insurance (for motor insurance).
If you purchase a motor vehicle from us, we will collect your name, date of birth, contact details, drivers licence details and any other information we may require.
If you are one of our suppliers or contractors or one of their employees, we may collect your name, contact details and position in the organisation.
If you apply for a job with us, you may provide us with certain information, including your name, employment and educational background, and other personal information which we may require you to provide, or which you choose to provide us, in relation to your job application.
If you are a subscriber to our mailing list or newsletter, or attended an event organised by Suttons, we may collect your name, contact details, job title, areas of interest and details of your dealings with us.
Generally Suttons does not collect sensitive information about you, such as health records, unless it is reasonably necessary for the purpose of providing you with a specific product or service or is otherwise permitted by law.
You can browse through our websites, including searching for a vehicle, without registering any of your personal information. Our websites collect personal information about you only when you complete a form on our websites and send it to us.
How do we collect personal information?
Suttons may collect personal information from you in a variety of ways including, without limitation:
on vehicle purchase contracts,
through our website,
over the telephone; or
during person-to-person contact.
The collection will be done by lawful and fair means and not in an unreasonably intrusive way. We will collect information directly from an individual wherever possible. If this is not possible, we will take reasonable steps to ensure that the individual is made aware of the information being collected is outlined in the collection statement.
If the information we request for the provision of products or services is not provided to us, then this may affect our ability to provide those products or services to you.
How does our website collect personal information?
When you visit our website, our server logs the following information provided by your browser (which does not personally identify you):
the type of browser and operating system you are using the previous site that you visited
your server's IP address (a number which is unique to the machine through which you are connected to the Internet: usually one of your service provider's machines).
Our server logs the date and time of your visit, which pages of our website you visited and any documents you downloaded.
Why do we collect and use your personal information?
Suttons will only collect personal information in connection with the provision of products and services provided by Suttons, our website or other business activities of Suttons.
We collect personal information only to the extent that this is necessary for one or more of our following activities:
relevant to our business relationship with you;
selling you a new or used motor vehicle and registering that vehicle in the name provided by you. We are required by law to provide certain information to the relevant licensing authorities and motor registries;
sale of products and services to you through our website;
completing 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;
completing an application for the provision of insurance cover;
providing after-sales service for your vehicle;
to offer you new products and services that we believe may interest you;
market research in relation to the products and services that we offer; and
to satisfy any legal requirements.
Generally, the purpose for which Suttons collects personal information will be apparent from the way in which we collect it, or will be disclosed at the time of collection. If at any time the purpose for which we are collecting your personal information is unclear, please raise your concerns with the person you are dealing with or contact us using the contact details below.
We will reply to your email address for the purpose for which you provide it.
We may also use your email address to respond to feedback given about our website, and to confirm receipt of emails sent to us.
When do we disclose your personal information?
Suttons discloses your personal information to related entities of Suttons or third party service providers and contractors who assist in our internal business and administrative operations. When we engage the services of a third party, we take reasonable steps to ensure they comply with the Privacy Act and maintain the confidentiality of any personal information to which they have access.
Suttons may disclose your personal information to the vehicle manufacturers, distributors and financiers for the purposes of supplying products and services that you request and contacting you for promotional, safety, market research purposes and other matters relating to the motor vehicle and you. The manufacturer, distributor and financier may disclose your personal information to certain organisations, such as marketing and research companies and other contractors for the purposes outlined above. Please visit www.suttons.com.au to view the privacy policies of the manufacturers we are associated with.
Suttons may disclose your personal information to organisations offering you insurance, finance and extended warranties.
We may disclose your personal information to fulfil legal requirements, such as disclosure to law enforcement agencies or the courts.
With your consent, we do allow your personal information to be provided to select organisations that perform certain functions or operations for us. We bind these companies to the same standard of care as we do ourselves.
We will not provide your personal information to any other organisation for marketing purposes without your consent and will not share, sell or trade your personal information to non-related companies or persons.
Will we disclose your personal information overseas?
Suttons does not ordinarily disclose your personal information overseas. However there may be circumstances where we need to disclose your personal information to a third party and this third party may disclose your personal information overseas. This may occur, for example where we have to send your personal information to the manufacturers, distributors and or financiers and they will on-send that information to their overseas headquarters or related companies.
APP 8.1 requires that we will take all reasonable steps to ensure that the third party recipient of your information complies with the APPs (other than APP 1) in relation to your personal information, or that the third party recipient is bound by laws that offer you at least as much protection as the APPs and that you are able to enforce your rights under those international laws in the event of any breach.
How do we ensure your personal information is correct?
We will endeavour to ensure that the personal information we collect and hold about you is complete, accurate and up to date. We use technology, documented procedures and internal review processes to assist in this process. To assist, please contact us at email@example.com if any of the details you have provided are incorrect or have changed.
Security of your personal information
Suttons is committed to keeping your personal information secure.
We take reasonable steps to protect the personal information that we hold from misuse or loss and from unauthorised access, modification or disclosure.
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. Suttons does not accept responsibility for the security of information transmitted to us over the internet.
Passwords, firewalls and virus protection are used to protect Suttons' systems holding personal information from unauthorised access.
Our website may contain links or plug-ins to other sites. We are not responsible for the content of or the practices or policies of, those sites.
Your credit card details will not be stored after the completion of the transaction. We will destroy or permanently de-identify all other personal information no longer needed for any purpose in accordance with the APPs.
Any personal information you provide to purchase merchandise on-line, including credit card details will be protected by 128 bit Encryption Security provided by a Thawte SuperCert.
To view this site securely, you need a browser that supports the SSL security protocol. These browsers will indicate whether or not the site is secure by displaying a symbol such as a key or lock, to show you are in secure mode; if not, a warning will appear when you are about to send information not in secure mode.
How can you access and correct your personal information?
You have the right to access your personal information held by Suttons. You can also make a request for us to correct any inaccurate, incomplete or out-of-date personal information.
For security reasons, a written request may be required to access your information as well as providing proof of your identity.
We are committed to granting you access to your personal information within a reasonable time frame. We will not refuse you access unless there are legal reasons for doing so. In such circumstances, we will explain those reasons to you. This may be necessary so that Suttons can ensure that your personal information is not disclosed to any other person.
If you consider that the personal information that we hold about you is not accurate, complete or up to date then we ask that you provide to us in writing with the correct information so the personal information held about you is accurate, complete and up-to-date.
There will generally be no charge for access to and supply of personal information. However, in cases where information has to be retrieved from archives or where large volumes of information has been requested, a reasonable fee might be charged to cover any costs incurred by Suttons.
Links to Other Sites
Our website links to websites of third parties. We are not responsible for the privacy practices of those parties.
How do we deal with privacy complaints?
Your privacy is important to Suttons and we will make every effort to resolve your concerns. To assist us in helping you, we ask you to follow a simple three-step process.
Gather all supporting documents about the matter of complaint, think about the questions you want answered and decide on what you want us to do.
Telephone us on +61 2 9357 1777, and we will review your situation and if possible, resolve it straight away.
If you are not satisfied with our response, we may require you to submit your complaint in writing by email at firstname.lastname@example.org with your contact details or via mail to:
The Privacy Officer
Suttons Motors Group
Level 1, 134 William Street, Potts Point NSW 2011
We will then investigate your complaint and endeavour to respond to you in writing within 30 days of receipt of your written complaint.
If at this stage the matter has not been resolved to your satisfaction, you can telephone the Australian Information Commissioner's hotline on 1300 363 992 or, if calling from outside Australia, + 61 2 9284 9749.
Contact us about privacy
Please direct your privacy related questions and feedback to Mr Robin Blackburn on +61 2 9357 1777 or email@example.com.
Further information about privacy
Further information may be obtained on privacy issues in Australia by visiting the Australian Information Commissioner's website at http://www.privacy.gov.au.
Date last revised: April 2014
GM Holden Ltd (Holden) recognises the importance of protecting an individual's privacy. We appreciate that individuals are concerned about the security of their personal information and we are committed to protecting any personal information we hold.
Personal information is information or an opinion about an individual who is reasonably identifiable.
Holden dealers are independent of Holden and have privacy policies which differ from ours. Holden dealers are responsible for their own privacy policies and privacy practices. Please contact your Holden dealer directly for further information.
COLLECTING PERSONAL INFORMATION
Holden will be fair and open about the way we collect information about you and what we intend to do with the information.
Holden may collect and hold personal information about you such as your name, address, telephone number, driver's license, date of birth, your vehicle's vehicle identification number, registration date, registration number, change of address and telephone information, amount of your GM Holden MasterCard rebate and the expiry date of your rebate points, and any other information you may voluntarily provide to us.
Holden collects most personal information directly from you, for example when you provide information through market surveys, product focus groups, the websites operated by Holden, Holden's customer assistance service (Customer Care) via mail, email and telephone enquiries, and during the recruitment process. Third parties may also share information with us, including our Dealers (such as vehicle purchasing, servicing and warranty information), related companies and Westpac (if you have a GM Holden MasterCard, Westpac provides Holden with some information for the purposes of ensuring that card holders are able to claim their GM Holden MasterCard rebate when purchasing an eligible Holden vehicle). We may also collect your personal information if you enter a competition or promotion we run (either directly or through our marketing agents), or through a recruitment or employment agency.
We may collect information about Dealer staff directly from those staff or from our Dealers, and about staff of our suppliers directly from those staff or from other staff of those suppliers. The information we collect about Dealer staff may include your name, position, contact details and training records. The information we collect about staff of our suppliers may include your name, position and contact details.
Other than the personal information set out in this policy, Holden does not collect any credit information about you. If we receive information about you from a third party, wherever practical we will make sure they undertake to comply with the Privacy Act.
Holden vehicles, like other modern motor vehicles, have a number of sophisticated computer systems that monitor and control several aspects of the vehicle's performance. Holden vehicles use on-board vehicle computers to monitor emission control components to optimize fuel economy, to monitor conditions for air bag deployment and, if so equipped, to provide anti-lock braking and to help the driver control the vehicle in difficult driving situations. Some information may be stored during regular operations to facilitate repair of detected malfunctions; other information is stored only in certain collision events by computer systems, such as those commonly called event data recorders (EDR). The information from EDR's, if available, is used to improve customer and driver safety, better understand what happens to our vehicles in the event of a collision and shall be provided to the police on request.
USING PERSONAL INFORMATION
Holden only collects, holds and handles information about you that is necessary for us to perform the services you request from us, that is otherwise reasonably necessary for our business activities or if required by an Australian law or court or tribunal order.
We may use personal information we collect about you for a number of purposes including:
to tell you about other products and services that may be of interest to you;
to learn more about your level of satisfaction, your expectations of us and our Dealers and how we can meet them (for example, in relation to Holden's products and services, and the products and services provided by Dealers and contracted service providers such as Roadside Assistance);
to ensure that any warranty claim is properly administered;
to run a competition or promotion you have entered;
to consider you for a position at Holden for which you have applied;
to acquire goods or services from you or from your employer;
to ensure that you are contacted as soon as possible in the event of a safety-related product recall;
to improve driver safety and to better understand what happens to Holden vehicles in the event of a collision;
for other purposes to which you have consented; and
as required or permitted by relevant laws and regulations.
Generally, we may use your personal information for the purposes for which we collected it and for related purposes which would be reasonably expected by you.
If you do not provide your personal information, Holden is less able to perform the above functions.
DISCLOSING PERSONAL INFORMATION
Holden may need to disclose personal information outside of the jurisdiction from which it was collected. When we disclose your personal information overseas, Holden is generally required to take reasonable measures to ensure that your information is held, managed and accessed in accordance with the standards that apply in Australia. In relation to health information about an individual, we will generally only disclose the information outside of the state or territory where we collected it if we reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which upholds principles for fair handling of the information that are substantially similar to the principles that apply in the state or territory of collection.
We may disclose personal information we collect about you for different purposes including:
to assist our related companies (such as General Motors and Holden New Zealand) and other service providers (such as information technology service providers, payroll service providers, recruitment service providers, third parties that provide services in relation to Holden's internal feedback and reporting programs i.e. Awareline program, service providers who assist us with "onboarding" new staff, mailing houses, Holden Assist, Holden Roadside Assistance) so that they can provide the services that we have contracted out to them;
to provide information to our Dealers so that they can provide goods or services to you or respond to a complaint by you, or to help them improve the quality and standard of service they provide to you;
to your nominated referees so that we may check your references if you are applying for a position with Holden; and;
as required by relevant laws and regulations.
Holden may disclose personal information to such entities located in the following countries/regions:
other countries in Europe;
the Middle East;
We will not sell, rent or trade your information to/with any other organisation.
We may require your consent to use and/or disclose your personal information if we need to use your information for a purpose that is not related to the purpose for which it was collected.
If you do not consent to Holden collecting, using and/or disclosing your personal information, this may affect Holden's ability to deliver and improve its products and services.
MARKETING AND PRIVACY
Holden sends marketing materials to its customers and other people who have provided Holden with personal information from time to time about products and services offered by Holden, its Dealers and its affiliates.
If you do not wish to receive marketing materials from Holden, its Dealers or its affiliates, please complete the opt-out provision on the marketing information sent to you and return it to Holden (or contact Holden Customer Care on 1800 033 349 or at firstname.lastname@example.org). Holden will note your request and respect your wish not to receive any marketing materials.
If you choose not to receive any marketing materials from Holden, you may miss out on special product and service offerings and opportunities.
PROTECTING PERSONAL INFORMATION
Holden will keep your personal information secure by taking reasonable steps to protect it from misuse, loss and unauthorised access, modification and disclosure.
Holden stores personal information in transmission logs and archive systems for a period Holden considers reasonable depending on the primary purpose for which that information was collected. Only properly authorised people who have a need to access personal information to perform their job will be able to see or use that information. The physical and electronic security systems at Holden comply with the guidelines of the Information Commissioner.
Personal information will be de-identified or destroyed when it is no longer required such that it cannot be re-identified at a later date. The de-identification and destruction process will be in accordance with the guidelines of the Information Commissioner.
Holden will ensure that its employees receive training (and refresher training) about the management of personal information relevant to their respective roles and responsibilities.
ACCESSING AND REQUESTING CORRECTION OF PERSONAL INFORMATION
We will strive to ensure that information about you is accurate when we collect or use it. Subject to some exceptions under the privacy legislation, we will let you see the information we hold about you and correct it if it is inaccurate, incomplete or out-of-date. If we do not grant you access to your personal information we will tell you why.
If you wish to obtain access to and/or correct your personal information held by Holden, please contact Holden Customer Care on 1800 033 349 or email us at email@example.com.
Holden will provide written acknowledgement of receiving your request for access within 7 days of receipt. Unless it does not agree to your request for access to personal information, in most cases Holden will provide you with access within 30 days of receipt of your request. If you request corrections to your personal information and Holden agrees with your request, these changes will be made as soon as practicable. If Holden does not agree to your request for correction, it will notify you of the reasons it does not agree and will note your request on the records it holds about you. If you remain dissatisfied you may also complain to the Information Commissioner (at www.oaic.gov.au).
RESOLVING YOUR CONCERNS
If you have a complaint regarding Holden's management of your personal information, please prepare your complaint in writing and email it to us at firstname.lastname@example.org.
Holden will provide written acknowledgement of your complaint within 7 days of receipt. We will investigate and advise you of the steps we have taken to resolve your complaint within 30 days of receipt of your complaint.
PRIVACY AND HOLDEN EMPLOYEES
However, Holden recognises that employee records should nevertheless be handled carefully, and Holden will comply with any obligations that may apply to employee personal information under other applicable laws.
Holden may disclose personal information held in its employment records for different purposes including: to our related companies (such as General Motors and Holden New Zealand) and to service providers (such as information technology service providers, payroll service providers, recruitment service providers, third parties that provide services in relation to Holden's internal feedback and reporting programs i.e. Awareline program and service providers who assist Holden with "onboarding" new staff) so that they can provide the services that Holden has contracted to them to perform.
Holden employees may seek to access, update or correct the personal information which Holden holds about them by contacting their Human Resources Manager. Such requests will be assessed on a case by case basis.
(a) independent contractors;
(b) secondees into Holden who remain employees of the seconding client or firm;
(c) voluntary work experience students; or
(d) job applicants.