YOUR PRIVACY IS OUR POLICY

This policy applies to us, Bill Hull Car Centre Subaru (ABN 56 052 293 606). In it, we will outline our obligations in managing the personal information you have shared with us. You might be a customer, a potential customer, a contractor or anyone else who has come into contact with us or our related companies. But whoever you are, we’re glad you’re here and we want you to enjoy your experience, both online and offline.

So rest assured, we take absolute care to respect your privacy. We are bound by the Australian Privacy Principles (‘APPs’) contained in the Privacy Act 1988 (Cth) (‘Privacy Act’) that require us to handle your personal information responsibly. ‘Personal Information’ is defined within the Privacy Act as information or an opinion about an individual, which can be used to identify that individual.

In this policy, we lay out all the information that we’re required by law to notify you of regarding how we collect, store, use and disclose your personal information.

WHY DO WE COLLECT YOUR INFORMATION?

We’ll collect your information for a number of reasons, including:

• to respond to enquiries regarding the products and services that we and/or our authorised retailers offer;

• to provide and market our products and services;

• to administer customer and warranty claims and service and recall campaigns;

• to inform you of offers and events and to facilitate and process your ordering of any special offers, products and services;

• to help us manage, develop and enhance the products and services that we and/or our authorised retailers offer, to create a better, more personalised experience for you; and

• to meet our legal obligations.

In most cases, we only use your information for the primary purpose it was collected. We’ll tell you what the primary purpose is at the time of collection and we’ll let you know any reasonably expected secondary purposes too. We don’t need to know any sensitive information about our customers (e.g. ethnic origin, political opinions, etc.) and will never ask you for this because, as we’re sure you’d agree, it’s just not necessary. We also take reasonable steps to provide clear, complete and up-to-date information about our business and the products and services we offer, like how to get in touch with us. This kind of information helps you to make informed choices.

If you don’t want to provide us with your personal information, we might not be able to respond to your enquiry or provide you with our products and services. For example, if you’ve purchased one of our cars, we might not be able to notify you of a recall or a safety or warranty related matter. So it’s best if you share some contact details with us.

WHAT KINDS OF INFORMATION DO WE COLLECT?

We’ll normally just collect names, addresses, contact details and any other relevant information that will help us provide our products and services.

HOW DO WE COLLECT IT AND HOW CAN YOU ACCESS IT?

When we collect your personal information, we’ll always try to tell you who we are and what we intend to do with it. We strive to be open. So upon request, we’ll always let you know what sort of information we hold about you, how we collect it and how we use and disclose it.

In line with the Privacy Act, you can request access to this personal information by contacting the Privacy Officer here at Bill Hull Car Centre Subaru – see the contact details below. You’ll just need to verify your identity and let us know what information you’re after. If you do make such a request, we may seek reimbursement of our reasonable costs in complying with your request. And we will let you know if this is necessary in our response to your request. We will always take steps to ensure that your personal details are accurate, complete and up-to-date when we use or collect them. You have the right under the Privacy Act to request changes to your personal information and we encourage you to contact us in order to update any information we hold about you using the Privacy Officer contact details set out below.

We’ll only ever collect your personal information by lawful and fair means. This is mainly by forms that you fill out (either online or in hard copy), business cards, in face-to-face meetings or interviews and third parties (e.g. companies we contract to collect data on our behalf). From time to time, we may also collect non-personal information e.g. information specific to a vehicle or model. This helps us in our ongoing efforts to improve our products and services.

WHAT ABOUT ANALYTICS, SESSIONS AND COOKIE TOOLS?

We use a range of tools provided by third parties, including Google, Bing and Marketo, to collect or view website traffic information. These sites have their own privacy policies explaining how they will treat the information they collect. We also use cookies and session tools to improve your experience when accessing our websites. The information collected by these tools will not include “personal information” as such, but may include the IP address of the device you are using and information about sites that IP address has come from, the pages accessed on our site and the next site visited. We use that information to maintain, secure and improve our websites and to enhance your experience when using them.

With Google Analytics, you can opt out of the collection of this information using the Google Analytics Opt-out Browser Add-on.

Third parties may use cookies to collect information about the content you view on our website. They’ll do this to serve you advertising on their websites that’s more relevant to you. If you wish to opt out, most Internet browsers allow you to change your settings to manage or block these cookies. Please note that this may limit your ability to use personalised features that we offer on our websites.

WHAT ABOUT SOCIAL MEDIA?

Like most brands these days, we use social networking services such as Twitter, Facebook and YouTube. When you communicate with us through these services, we may collect some of your personal information. But we only use it to help us better communicate with you and the public. The social networking service will also handle your personal information for its own purposes. These sites have their own privacy policies too.

WHO ELSE MIGHT SEE YOUR INFORMATION?

We may disclose your personal information to:

• our related companies;

• the manufacturer of vehicles that we sell;

• insurance companies;

• credit providers;

• state government entities responsible for motor vehicle registrations and driving infringements;

• other companies or individuals who assist us in providing services or who perform functions on our behalf (such as mailing houses or our live chat service provider) who are generally contract-bound to protect your privacy;

• law enforcement bodies such as the police, who seek access to your personal information for law enforcement purposes; and

• anyone else to whom you have authorised us to disclose it.

We may also collect your personal information from these companies, organisations and individuals. If we do, we’ll only deal with this information in accordance with this policy.

If we do disclose your personal information to others, we’ll make sure we have your consent – implied or expressed – first (unless we are compelled by law to disclose without your consent). And we’ll take steps to ensure the next party agrees to protect the privacy of your personal information too.

SENDING PERSONAL INFORMATION OVERSEAS

Sometimes we might disclose your personal information to entities located outside Australia. When this happens, we’ll always take steps to ensure the recipients respect the confidentiality of your information by abiding by the APPs (or equivalent) privacy laws. These entities may include the actual manufacturer of Subaru vehicles, Subaru Corporation (SBR) in Japan, our parent company in the UK and our live chat service provider in the USA.

Other than those three above, we’ll never send your personal information to recipients outside of Australia without:

• obtaining your consent (in some cases this consent will be implied); or

• otherwise complying with the APPs.

ELECTRONIC COMMUNICATIONS

The Spam Act 2003 prohibits us from sending you any commercial electronic communications, such as texts and emails containing marketing offers, without your consent.

So in line with our commitment to technology (but within the parameters of the law), we like to accommodate customers who want to be contacted electronically. We might send you communications for any of the purposes mentioned above.

When we collect your personal information, we might ask you for your mobile phone number or email address. When you provide these details, we’ll also request your consent for us to use these details for commercial electronic communications. Whenever such messages are sent, we’ll always provide you with the option of opting out of receiving similar communications in the future within the message.

DO NOT CALL REGISTER

The Do Not Call Register Act 2006 prohibits the making of telemarketing calls (as defined in the legislation) to numbers listed on the Do Not Call Register. In line with our commitment to corporate compliance, we will only contact numbers that appear on the Do Not Call Register in the limited circumstances allowed by the Do Not Call Register Act 2006 and the Telecommunications (Do Not Call Register) (Telemarketing and Research Calls) Standard 2007, such as where you have given us the requisite consent to do so. Where you give us express consent to contact you by phone, we’ll deem it to be supplied for an indefinite period for the purposes of the Do Not Call Register Act 2006, unless otherwise advised or withdrawn by you.

OPTING OUT

We will always provide individuals with an opportunity to opt out of receiving direct marketing communications from us. If you have received a direct marketing communication from us and do not wish to receive these communications from us in the future, just use the “unsubscribe” function in the email or SMS, or tick the opt out box on postal communications and return the mailed item to us. Otherwise just use the “Contact Us” form on our website or write to or email the Privacy Officer using the details below, and we’ll take appropriate steps to ensure you won’t receive any direct marketing communication from us in the future. Please note that where you have opted out, we may keep your details to make sure you don’t receive further communications. We might also need to contact you in relation to matters such as vehicle safety, recalls, warranty and for requirements specified by law. You should also note that your Subaru Retailer is a separate organisation to Subaru Australia. This means your Subaru Retailer may still send you information about Subaru products and services, independently of Subaru Australia. If you do not wish to continue receive such information, simply contact your Subaru Retailer and let them know.

OUR SECURITY

We take all reasonable steps to protect the security of personal information collected by us. Your peace of mind is everything when it comes to providing your personal information. So we have developed ways to ensure that your personal information is safe and protected against misuse, loss or unauthorised access, modification or disclosure. Rest assured that where we no longer require your personal information for a permitted purpose under the APPs, we’ll take all the reasonable steps to destroy or suppress your personal information.

YOUR COMPLAINTS

If you have a concern with the collection, disclosure, storage or use of your personal information, just let us know. You can make a complaint, obtain redress or pursue dispute resolution by contacting our Privacy Officer using the details set out below. The Privacy Officer shall review, investigate and respond to any privacy complaint within 10 working days of receiving your complaint. The Privacy Officer will let you know if they can’t meet this time frame, usually only if the complaint is complex or requires more extensive investigation.

EMPLOYEE RECORDS

Due to an exemption in the Privacy Act, this policy does not apply to our treatment of an employee record, where that treatment is directly related to the current or former employment relationship between us and the individual.

UPDATES TO THIS POLICY

This policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. We will always make any information regarding our Privacy Policy available to anyone who requests it, whether at our offices or on our website.