Privacy Policy

Background

1. General

   Volvo Cars Geelong (ABN 75 006 175 515) (we, us, our) is a car dealership selling new and used vehicles.

   We are committed to protecting your privacy, in accordance with applicable Australian privacy laws. This Policy is designed to give you a greater understanding of how we collect, use, disclose and otherwise handle personal information.

   This Privacy Policy applies to all persons who interact with us ('you/your'), including everyone who visits or uses our website, anyone who uses any of our products and services and our staff. This Privacy Policy applies to our collection and use of your personal information. By visiting and/or using our website and obtaining our products and services and otherwise dealing with us, you agree to the terms and conditions of this Privacy Policy.

2. What is personal information?

   Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable. Examples include your name, address, date of birth and email address.

3. Our obligations

   We are required to comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, security, accessibility and disposal. We are also required to comply with more specific privacy legislation in some circumstances, such as the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).

What we collect

1. General

   The type and amount of personal information that we collect about you depends on the type of dealings you have with us. For example, depending on the context we may collect:

   • your name
   • your job title
   • your address
   • your telephone number
   • your email address
   • your social media profile
   • your cover letter, resume, and referee reports (for job applications)
   • your driver licence number
   • your vehicle details
   • your location
   • your ABN
   • any other relevant and necessary information to enable us or Volvo Car Australia Pty Ltd (VCA) to provide Volvo products and services to you and/or to support your purchase of any Volvo products or services.

2. Sensitive information

   Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection, such as health information. We only collect sensitive information where it is reasonably necessary for our activities and either you have consented or we are required or authorised by or under law to do so.

   For example, we may collect:

   • health information (for life or disability insurance)
   • details of current or previous insurance (for motor insurance)
   • salary and personal finances (for loan applications)
   • bank or credit card account details

3. Collection of information other than personal information through our website

   When you visit our website, some of the information that is collected about your visit is not personal information, as it does not reveal your identity.

   Site visit information

   For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.

   We use and disclose this information in anonymous, aggregated form only, for purposes including statistical analysis and to assist us to improve the functionality and usability of our website. You are not individually identified, however we reserve the right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.

   Cookies

   A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users, although they do identify the user's internet browser.

   We use cookies to hold anonymous session information. This information is used to personalise your current visit to the website, for example to allow the website to remember who you are by keeping server variables linked to your session. We only use non-persistent cookies. That is, they are held on your browser's memory only for the duration of your session.

   Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. Rejecting cookies can, however, limit the functionality of our website.

4. What if you don't provide us with your personal information?

   We will provide you with the option of not identifying yourself, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to your actual name. For example, you can access our website and make general phone queries without having to identify yourself.

   In some cases however, if you don't provide us with your personal information when requested, we may not be able to provide you with the product or service that you are seeking. For example, you must identify yourself to purchase a vehicle.

How we collect personal information

1. Methods of collection

   We collect personal information in a number of ways, including:

   • in person (for example, when you come to our dealership or events)
   • through our website (for example when you submit a request to receive our offers, to receive our brochures and/or other materials, or to book a test drive)
   • when you buy a vehicle from us
   • through our Facebook page or other social media accounts
   • over the telephone
   • through written correspondence (such as sms, letters, faxes and emails)
   • any materials about our vehicles, parts, accessories or services (for example, competition entry forms and surveys)
   • through surveillance cameras
   • from third parties, including:
     • manufacturers, distributors and VCA's authorised dealer network and service providers
     • marketing organisations including through the use of purchased lists industry databases
     • publicly available sources such as the internet and telephone directories

2. Collection notices

   Where we collect personal information about you, we will take reasonable steps to provide you with certain details about that collection (such as the purpose for which we are collecting the information and the type of third parties to which it is usually disclosed). We will generally include this information in a collection notice.

   Collection notices provide more specific information than this Privacy Policy. The terms of this Privacy Policy are subject to any specific provisions contained in collection notices and in the terms and conditions of particular offers, products and services. We encourage you to read those provisions carefully.

3. Unsolicited information

   Unsolicited personal information is personal information we receive that we have taken no active steps to collect (such as an employment application sent to us by an individual on their own initiative, rather than in response to a job advertisement).

   We may keep records of unsolicited personal information if the Privacy Act permits it (for example, if the information is reasonably necessary for one or more of our activities). If not, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.

Why we collect personal information

1. General

   The main purposes for which we collect, hold, use and disclose personal information are set out below:

   • promoting ourselves and VCA and each of our products and services, including through direct marketing, events and competitions (see under heading 4.2 below)
   • to manage our and VCA's relationship with you and to provide you with Volvo products and services;
   • administering your vehicle's warranty
   • supporting you in making an application for finance or insurance for your vehicle
   • obtaining products and services for our business
   • performing research and statistical analysis, including but not limited to for market research, customer satisfaction and service improvement purposes
   • protecting the security of our offices, staff, customers and the property held on our premises
   • answering queries and resolving complaints
   • monitoring performance and to help us and VCA manage our respective products, services and business operations
   • training our and VCA's respective employees, agents and representatives
   • recruiting staff and contractors
   • complying with our legal obligations (e.g. in relation to a vehicle safety recall)
   • handling complaints and disputes; and detect, investigate and prevent fraud.

   We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection, to which you have consented or which are required or authorised by or under law.

2. Direct marketing

   We may use or disclose your personal information to let you know about us and our products and services (including promotions, special offers and events), either where we have your express or implied consent, or where we are otherwise permitted by law to do so. We may contact you for these purposes in a variety of ways, including by mail, email, SMS, telephone, or online advertising.

   Opting out

   Where you have consented to receiving marketing communications from us, your consent will remain current until you advise us otherwise. However, you can opt out at any time, by:

   • contacting us (details under heading 11 below)
   • Collection of Personal Information You can browse through this website, including searching for a vehicle, without registering any of your Personal Information. This Website collects Personal Information about you when you complete a form on the Website and send it to us. When we collect, store, or use information about you we try at all times to comply with the national Principles for the Fair Handling of Personal Information. We do not disclose any information collected on the Website to any organization not related to this company. When you provide us with information on this Website we may ask your permission to contact you in the future about products or promotions related to this company. If you give your permission you will be given the opportunity to withdraw it at any later time we contact you If you do not give our permission you will not be contacted again except as it pertains to your specific request. Information collected by our Server. When you visit this site, 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. Our server might use a feature of your browser called a "cookie" to assign a user ID. Cookies identify your computer to our server when you visit our site. We only use cookies to store the sites or databases that a user has selected, Cookies are not used for any other purpose. You do not need to have configured your browser to enable the accepting or sending of cookies in order to use this site. We only use the information collected by our server to generate statistics and analyse site activity. How we use Personal Information collected about you We will reply to your email address for the purpose for which you provide it. If you give permission we will use your personal information (see below for what Personal Information we collect) only to send you emails to announce products or promotions related to this company. Every time we send you an email, we will give you the opportunity to choose not to receive further emails of that type. We may also use your email address to respond to feedback given about this site, and to confirm receipt of emails sent to us. What personal information do we collect? When you send a form on this Website to us, it will provide the following Personal Information: Your name Your email address On some forms it will additionally ask for: Your phone number Your fax number Your address When booking a vehicle service, details of your vehicle When ordering merchandise, your Credit Card details Security of your Personal Information 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 such as Netscape Navigator or Microsoft Internet Explorer displaying a symbol such as a key or lock, to show you are in secure mode; if not, a warning will appear. Please note despite the high level of security installed on this website, we cannot guarantee that any e-mail is secure. Your credit Card details will not be stored after the completion of the transaction. Access to your personal information. If you have any questions about this Privacy statement or if you wish to gain access to the information that we may have collected about you, please contact the Privacy Officer. If any of the Personal Information we are holding has changed, we will correct it for you.
   • advising us if you receive a marketing call that you no longer wish to receive these calls
   • using the unsubscribe facility that we include in our electronic messages (such as emails, SMSes and MMSes)

Who we may share your personal information with

We may share personal information with third parties where appropriate for the purposes set out under heading 4, including:

• VCA, who may use, disclose, share and store your personal information in accordance with their privacy policy which can be found at www.volvocars.com/au/footer/privacy.
• vehicle manufacturers and distributors
• financial institutions for payment processing
• insurers
• government, regularity and law enforcement authorities and organisations as required or authorised by law
• our related body corporates
• an individual's agent or authorised representative
• your employer (where applicable)
• referees whose details are provided to us by job applicants
• our or VCA's contracted service providers: including, roadside assistance, customer research, delivery and shipping providers, information technology and data storage providers, customer relationship management platforms, venues and event organisers, marketing and communications agencies, research and statistical analysis providers, call centres, mailing systems
• external business advisers (such as consultants, recruitment advisors, accountants, auditors and lawyers)
• the agent(s) of any of these entities referred to above

In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services. In some cases, we may also disclose personal information where you consent to us doing so. This consent may be written, verbal or implied from your conduct.

These entities are not authorised by us to use personal information for anything other than the purpose for which we supplied that information to them.

Cross border disclosure of personal information

We may disclose personal information to third parties located overseas to the following recipients:

• vehicle manufacturers and distributors;
• external advisers; and
• service providers (including information technology service providers).

The countries where these recipients may be located will vary from time to time. In each case, we will comply with the requirements of the Privacy Act that apply to cross border disclosures of personal information.

Use of government related identifiers

Unless permitted by the Privacy Act (for example, use of an identifier to verify an individual's identity or uses or disclosures required or authorised by or under an Australian law), we will not:

• use a government related identifier of an individual (such as a Medicare number or driver's licence number) as our own identifier of individuals; or
• otherwise use or disclose such a government related identifier,

Data quality and security

1. General

   We take reasonable steps to:

   • make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
   • protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and
   • destroy or permanently de-identify personal information that is no longer needed for any purpose permitted by the APPs.

   You can help us keep your information up to date, by letting us know about any changes to your details, such as your address, email address or phone number.

2. Security

   The steps we take to secure the personal information we hold include website protection measures (such as firewalls and anti-virus software), security restrictions on access to our computer systems (such as login and password protection), controlled access to our corporate premises, policies on document storage and security, personnel security, staff training and workplace policies.

   Online credit card payment security

   We may from time to time process payments using EFTPOS and online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.

   Website security

   While we endeavour to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone or post (details under heading 11 below).

   Third party websites

   Links to third party websites that are not operated or controlled by us are provided for your convenience. We are not responsible for the privacy or security practices of those websites, which are not covered by this Privacy Policy. Third party websites should have their own privacy and security policies, which we encourage you to read before supplying any personal information to them.

Access and correction

1. General

   Please contact our Privacy Officer (details under heading 11 below) if you would like to access or correct the personal information that we hold about you. We may require you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.

2. Access

   We will generally provide you with access to your personal information, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (eg by providing photocopies), provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.

3. Correction

   If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.

Complaints

If you have a complaint about how we have collected or handled your personal information, please contact us (details under heading 11 below).

We will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week. If we are not able to do so, we will ask you to submit your complaint in writing. In most cases, we expect to investigate written complaints and provide a response within 30 days of receipt. If the matter is more complex and our investigation may take longer, we will contact you and tell you when we expect to provide our response.

If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner (see https://www.oaic.gov.au/privacy/privacy-complaints/ for further information).

Our contact details

Please contact us if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details are set out below.

Mail: Volvo Cars Geelong Privacy Officer, 212 - 224 Latrobe Terrace, Geelong VIC 3220

Email: privacy@gorell.com.au

Telephone: (03) 4242 4752

Further general information about privacy is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au or by calling the OAIC's enquiry line at 1300 363 992.

Changes to this Policy

We may amend this Privacy Policy from time to time. The current version will be posted on our website and a copy may be obtained by contacting our Privacy Officer (details above).