Walkinshaw Automotive Group Pty Ltd trading as Walkinshaw Group Privacy Policy

(www.walkinshawgroup.com)

Walkinshaw Automotive Group Pty Ltd trading as Walkinshaw Group recognises the importance of protecting an individual’s privacy and is committed to complying with applicable privacy legislation which regulates the handling of personal information. 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, whether recorded in a material form or not, who is reasonably identifiable from that information.

In accordance with the 13 Australian Privacy Principles (‘APPs’) set out in the Privacy Act 1988 (Cth) (‘Privacy Act’)">, this Privacy Policy details how Walkinshaw Group will manage and protect personal information, including information that Walkinshaw Group collects and uses for the purpose of providing better customer service by striving to meet our customers’ needs and expectations about our cars and other products.

This Privacy Policy generally does not apply in relation to current or former Walkinshaw Group employees.

Walkinshaw Group dealers are independent of Walkinshaw Group and may have privacy policies which differ from ours. Walkinshaw Group dealers are responsible for their own privacy policies and privacy practices. Please contact your Walkinshaw Group dealer directly for further information.

Walkinshaw Group may amend this Privacy Policy at any time. The updated version will be available by following the ‘Privacy Policy’ link on Walkinshaw Group’s website homepage, at www.walkinshawgroup.com. Walkinshaw Group may highlight changes to this Privacy Policy on its homepage, but you should check the Privacy Policy regularly for changes.

Collecting personal information

Walkinshaw Group will be fair and open about the way we collect information about you and what we intend to do with the information.

Walkinshaw Group 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 and any other information you may voluntarily provide to us.

Walkinshaw Group collects most personal information directly from you, for example when you provide information through market surveys, product focus groups, the websites operated by Walkinshaw Group, Walkinshaw Group’s customer assistance service 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) and related companies. 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, Walkinshaw Group 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 Act.

Walkinshaw Group vehicles, like other modern motor vehicles, have a number of sophisticated computer systems that monitor and control several aspects of the vehicle's performance. Walkinshaw Group vehicles use on-board vehicle computers to monitor emission control components to optimize fuel economy, to monitor conditions for air bag deployment and to provide anti-lock braking and to help the driver control the vehicle in difficult driving situations.

Using personal information

Walkinshaw Group 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 Walkinshaw Group’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 Walkinshaw Group 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 Walkinshaw Group 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, Walkinshaw Group is less able to perform the above functions.

Disclosing personal information

Walkinshaw Group may need to disclose personal information outside of the jurisdiction from which it was collected. When we disclose your personal information overseas, Walkinshaw Group 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 and other service providers (such as information technology providers, mailing houses, Holden Assist and Holden Roadside Assist) 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 Walkinshaw Group; and;
• as required by relevant laws and regulations.

Walkinshaw Group may disclose personal information to such entities located in the following countries/regions:

• the USA;
• Spain;
• other countries in Europe;
• Africa;
• Oceania;
• South America;
• Asia; and
• the Middle East;

We will not sell, rent or trade your information to/with any other organisation.

Consent

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 Walkinshaw Group collecting, using and/or disclosing your personal information, this may affect Walkinshaw Group's ability to deliver and improve its products and services.

Marketing and privacy

Walkinshaw Group sends marketing materials to its customers and other people who have provided Walkinshaw Group with personal information from time to time about products and services offered by Walkinshaw Group, its Dealers and its affiliates.

If you do not wish to receive marketing materials from Walkinshaw Group, its Dealers or its affiliates, please complete the opt-out provision on the marketing information sent to you and return it to Walkinshaw Group (or contact Walkinshaw Group Customer Care at customer.care@walkinshawgroup.com). Walkinshaw Group will note your request and respect your wish not to receive any marketing materials.

If you choose not to receive any marketing materials from Walkinshaw Group, you may miss out on special product and service offerings and opportunities.

Cookies

We use cookies and track IP addresses via our websites so we can improve our services provided by our websites and enhance your user experience.

Cookies are pieces of information a website can send to your computer's browser for record-keeping purposes. We use cookies to ascertain which web pages are visited and how often, to make our websites more user friendly, to give you a better experience when you return to a website and to target advertising to you that we think you may be interested in. For example, cookies allow us to save your password so you do not have to re-enter it every time you visit our site. Most web browsers automatically accept cookies. Cookies can be disabled or purged from your browser if you so choose. You can find information specific to your browser under the “help” menu. We can’t guarantee the proper functioning of our websites if you choose to disable cookies.

Protecting personal information

Walkinshaw Group will keep your personal information secure by taking reasonable steps to protect it from misuse, loss and unauthorised access, modification and disclosure.

Walkinshaw Group stores personal information in transmission logs and archive systems for a period Walkinshaw Group 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 Walkinshaw Group 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.

Walkinshaw Group will ensure that its employees receive training (and refresher training) about the management of personal information relevant to their respective roles and responsibilities.

Walkinshaw Group will take reasonable steps to keep any personal information we hold about you secure. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory rights under any applicable law including the Privacy Act or the Competition and Consumer Act 2010 (Cth). Please notify us immediately if you become aware of any breach of security.

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 Walkinshaw Group, please contact Walkinshaw Group Customer Care at feedback@walkinshawgroup.com.

Walkinshaw Group 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 Walkinshaw Group will provide you with access within 30 days of receipt of your request. If you request corrections to your personal information and Walkinshaw Group agrees with your request, these changes will be made as soon as practicable. If Walkinshaw Group 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 Walkinshaw Group's management of your personal information, please prepare your complaint in writing and email it to us at feedback@walkinshawgroup.com.

Walkinshaw Group 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 Walkinshaw Group employees

Due to the "employee records exemption" in the Privacy Act, Walkinshaw Group is generally not required to comply with the Privacy Act in relation to personal information held in its employment records concerning current or former Walkinshaw Group employees. Therefore, this Privacy Policy generally does not apply in relation to current or former Walkinshaw Group employees.

However, Walkinshaw Group recognises that employee records should nevertheless be handled carefully, and Walkinshaw Group will comply with any obligations that may apply to employee personal information under other applicable laws.

Walkinshaw Group may disclose personal information held in its employment records for different purposes including: to our related companies and to service providers (such as information technology service providers, payroll service providers and service providers who assist Walkinshaw Group with onboarding new staff) so that they can provide the services that Walkinshaw Group has contracted to them to perform.

Walkinshaw Group employees may seek to access, update or correct the personal information which Walkinshaw Group holds about them by contacting their Human Resources Department. Such requests will be assessed on a case by case basis.

The employee records exemption does not apply (and this Privacy Policy does apply) to:

• (a) independent contractors;
• (b) secondees into Walkinshaw Group who remain employees of the seconding client or firm;
• (c) voluntary work experience students; or
• (d) job applicants.

Further questions

If you have any questions about this Privacy Policy or our privacy practices you can contact us at feedback@walkinshawgroup.com.

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