Echuca Subaru Privacy Policy

Servco Australia Echuca Pty Ltd ATF Servco Australia Echuca unit trust (ABN 85 712 251 405) (Echuca Subaru) aims to provide its customers with the best possible products and services. We also want our customers to have confidence that we afford personal information an appropriate level of privacy, consistent with the National Privacy Principles set out in the Privacy Act 1988 (Cth) and with the Spam Act 2003 (Cth).

Please note that Subaru Motor Corporation Australia Limited (Subaru Australia) operates separately to Echuca Subaru. For details of Subaru Australia’s Privacy Policy, see http://www.Subaru.com/help/privacy.html

What is Personal Information?

Personal information is information in any recorded form that identifies an individual or from which an individual’s identity can reasonably be ascertained. Examples include an individual’s name, address, contact number and email address.

With your consent your personal information may be shared by us with Subaru (Aust) Pty Ltd (“Subaru Australia”) Subaru Australia for the purposes of marketing or research.  Subaru Australia may use this personal information to communicate with you by phone, email or other means in relation to promotions and other Subaru deals.

Why does Echuca Subaru collect personal Information?

Echuca Subaru collects personal information for a range of purposes, including to:

• Respond to customer queries about the products and services that we offer
• Confirm that customers are properly licensed for the purposes of taking a test drive or using one of our hire vehicles
• Supply products and services (including new and used vehicles, parts, accessories and any applicable warranties)
• Process payment for products and services (including considering applications for credit where relevant)
• To coordinate delivery of your vehicle and ensure that your vehicle is delivered to your satisfaction
• Consider, process and record the purchase of trade-in vehicles
• Carry out vehicle repairs and servicing, supply parts and accessories, supply products such as lubricants and automotive fluids and maintain any applicable warranties
• Arrange for products and services to be supplied to customers by third parties (including Echuca Subaru sub-contractors) where appropriate (for example, extended warranty and roadside assistance services and financial and insurance products in respect of vehicles purchased from us; or fitment of non-genuine parts and accessories, panel beating services or windscreen replacement in respect of vehicles we are repairing) (these people may contact you directly for this purpose);
• To conduct competitions

Echuca Subaru also uses the personal information that it collects to:

• Maintain records for accounting and administration purposes
• Administer warranty claims
• Provide customer support
• Respond to customer complaints
• Administer safety-related product recalls
• Analyse customer needs and develop customer strategies
• Meet legal and regulatory requirements

Customer satisfaction surveys, service reminders and direct marketing

From time to time, Echuca Subaru surveys its customers on a range of issues, including new vehicle satisfaction and the quality of our service. These surveys help us to improve our products and services and tailor the way that we do business with you. If you do not wish to participate in these surveys, please contact Echuca Subaru on (03) 5482 3377 or via info@echucaSubaru.com.au

If you consent, Echuca Subaru may use your personal information to send you service reminders and information about our products and services, including special offers. We may also send our customers information about products and services of businesses associated with Echuca Subaru. If you no longer wish to receive this information, please contact Echuca Subaru (details provided at the end of this policy).

If you do not wish to receive Customer Satisfaction Surveys or other marketing information from Subaru Australia, please contact Subaru Australia directly on 1800 252 0976 (you will still receive safety-related messages).

What sort of personal information does Echuca Subaru collect?

The type of personal information that we collect will depend on the circumstances of collection. For example, we may collect your name, date of birth, address, telephone number, email address and vehicle purchase and service history. For vehicle purchases, we also collect information such as the vehicle make, model and colour, options and accessories supplied, price paid, trade-in details, vehicle identification number, registration details, driver’s licence number, odometer reading, finance and insurance details and details of any roadside assistance services or extended warranty purchased. We may also collect details of other interactions that you have with us, together with any other information that you choose to provide us with.

The collection of sensitive information is restricted by the Privacy Act. Echuca Subaru will not collect sensitive information about an individual unless this is necessary for one of Echuca Subaru’s functions or activities and the individual has consented to that collection, or Echuca Subaru is otherwise required or authorised by or under law to do so.

How does Echuca Subaru collect personal information?

Much of the personal information that we hold is collected when you purchase a vehicle or parts and accessories from us, when you trade-in a vehicle or when you have your vehicle repaired or serviced by us. We may also collect personal information in a number of other ways, for example when you:

• Contact us with a query (whether in person, or by phone, fax, email, through the forms on the Echuca Subaru website or through carsales.com.au or drive.com.au)
• Take a vehicle for a test drive or use one of our hire vehicles
• Enter a competition conducted by us
• Respond to one of our direct marketing campaigns

If you have purchased a vehicle with the Subaru Link system, information such as vehicle diagnostic data, odometer reading, vehicle location and vehicle speed will be collected directly from your vehicle. Please refer to the Subaru Link Subscription Agreement for further details.

Website Collection of Information

Some of the information that is collected on our website is not personal information, because it does not reveal your identity. For example, we may record your server address, domain name, the date and time of your visit to this site and the pages that you viewed. This information is used by us in anonymous, aggregated form only, for statistical and web site development purposes.

However, Echuca Subaru reserves its right to use or disclose this information to try to locate an individual if it reasonably believes that the individual may have engaged in any unlawful or inappropriate activity in connection with this website.

A cookie is a small data file that a web site transfers to your internet browser for identification purposes. The cookies that we use do not identify you individually. Instead, they identify your internet browser.

We use cookies to maintain session information about you when you log into our website, which enables us to personalise your current visit.

Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can however limit the functionality of this website.

Third Party Collection of Information

Sometimes, we may collect your personal information from third parties, for example where:

• You respond to a Customer Satisfaction Survey conducted by Subaru Australia or a vehicle industry survey and the survey results are provided to Echuca Subaru
• We collect information such as your warranty details and service history from Subaru Australia or from another authorised Subaru dealer, to facilitate the provision of services to you
• We have arranged for third parties to supply you with products and services and those third parties provide us with information about the products or services that you have purchased from them (please note that we do not collect your credit or financial details from finance or insurance suppliers)

What if you don’t provide your personal information to Echuca Subaru?

If Echuca Subaru is unable to collect personal information from or about you, it may prove difficult to do business with you or the organisation with which you are connected.

When does Echuca Subaru disclose personal information to third parties?

In providing our customers with products or services, we may disclose personal information to third parties. In particular, your personal information may be disclosed to Subaru Australia, Subaru Motor Corporation (Subaru’s Japanese parent company) and their related bodies corporate. Information such as warranty details and service history may also be disclosed to other authorised Subaru dealers, to help them better serve your needs.

Other third parties with whom we may share your personal information include, where appropriate:

• Finance, insurance, extended warranty and roadside assistance providers (where you have requested that they supply products and services to you)
• Providers (including Echuca Subaru sub-contractors) of outsourced vehicle repair and maintenance services (such as panel beaters and windscreen repairers) (these people may contact you directly for this purpose)
• Valuers (to assess the value of your vehicle) and vehicle registries (to check whether a trade in vehicle is encumbered)
• Government authorities (for example for vehicle registration and compulsory third party (bodily injury) insurance or as required under financial transactions reporting or anti-money laundering legislation) police, local council authorities or our insurers if a test drive or hire vehicle is involved in any parking or traffic infringements or is damaged whilst in your possession
• Financial institutions for payment processing referees, referrals or guarantors whose details you have provided to us

Echuca Subaru’s contracted service providers, including:

• Website designers and information technology service providers
• Marketing and communications agencies
• Call centres and call training centres
• Mailing houses, freight and courier services
• Printers and distributors of direct marketing material
• External business advisors (such as auditors, lawyers and debt collectors)

In the case of contracted service providers, we may disclose personal information to the contracted service provider and the contracted service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services. We take steps to help ensure that our contracted service providers comply with the NPPs when they collect and handle your personal information.

We may also disclose personal information to third parties where required or authorised by or under law to do so with your consent (which may be written, verbal or implied from your conduct).

Spam

We will not send you any commercial electronic messages such as sms or emails without your consent. Any commercial electronic message that we send will identify Echuca Subaru as the sender and will incorporate our contact details. The message will also provide an unsubscribe facility. If you do not wish to receive commercial electronic messages from us, please Echuca Subaru (details provided at the end of this policy).

Ensuring personal information is up-to-date

We rely on the personal information we hold in conducting our business. We take reasonable steps to ensure that the personal information we hold is accurate complete and up-to-date.

Security of personal information

The security of information is important to Echuca Subaru and we take precautions to protect the personal information that we hold from misuse, loss, unauthorised access, modification or disclosure.

Some of the ways we protect personal information include:

• External and internal premises security
• Restricted access to personal information to staff who need it to perform their day to day functions
• Conducting training to ensure that staff are aware that they must only access, use and disclose personal information for appropriate purposes
• Requiring staff who have access to personal information to agree to protect the privacy of that information
• Maintaining technology products to prevent unauthorised computer access, including identifiers and passwords
• Maintaining physical security over paper records

How long does Echuca Subaru keep personal information?

We will take reasonable steps to destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the Privacy Act.

Use of Commonwealth government identifiers

We will not use Commonwealth government identifiers (“Identifiers”) (such as Medicare numbers) as our own identifier of individuals. We will only use or disclose Identifiers in the circumstances permitted by the Privacy Act.

Transfer of personal information overseas

If Echuca Subaru transfers your personal information outside Australia, we will comply with requirements of the Privacy Act that relate to transborder data flows. Please note that some of the servers on which Subaru Australia’s customer information is held are located overseas and owned by Subaru Motor Corporation (Subaru Australia’s Japanese parent company). As a result, personal information collected and held by Subaru Australia may be transferred overseas to be held on these servers.

Access to personal information by individuals

Please contact Echuca Subaru (details provided at the end of this policy) if you would like to access or correct the personal information that we hold about you. We will generally provide you with access to your personal information. Depending on the amount of information requested, Echuca Subaru may charge an access fee to cover the cost of retrieving the information and supplying it to you.

Access to personal information may be refused in a number of circumstances, such as where the information relates to anticipated legal proceedings or the request for access is frivolous or vexatious. If we deny or restrict your access, we will explain why. Similarly, in some limited circumstances we may not make requested corrections to personal information, in which case we will provide you with reasons for this decision.

Job applicants and employees

Any personal information provided to Echuca Subaru in connection with job applications may be used to consider the applicant for current and future employment and may be disclosed to our third party advisors to assist us in the selection and recruitment process.

If your application for employment is successful, Echuca Subaru will rely on the exemption in the Privacy Act relating to employee records where applicable.

Resolving concerns

If you have any concerns about the way your personal information is managed by Echuca Subaru, or believe that a breachf of your privacy has occurred, please let us know by contacting Echuca Subaru (details provided below). We will respond to your concerns as soon as possible.

Contact details and additional information

If you would like more information about Echuca Subaru’s approach to privacy, or if you wish to contact us regarding the information set out in this policy, please contact us:

Echuca Subaru

101 Northern Highway
Echuca
VIC 3564

Ph:          (03) 5482 3377

Fax:         (03) 5482 5537

Email:     info@echucasubaru.com.au

Changes to this policy

We may amend this policy from time to time at our discretion. Amended versions will be posted on our website at www.echucaSubaru.com.au and will be available from the Echuca Subaru.