MOC Enterprises (Aust) No2 Pty Ltd ACN 054 373 170, trading as Swan Hill & Kerang Toyota (Company, we, our or us) is committed to ensuring the privacy of the personal information we collect in the course of our business.  We believe that respect for your privacy forms part of our values.

We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and with the Spam Act 2003 (Cth).  The Australian Privacy Principles set out the way in which organisations can collect, use, keep secure and disclose personal, including sensitive, information.  The Privacy Act also generally gives individuals the right to know what personal information an organisation holds about them and the right to correct that information if it is wrong. Further information on the Australian Privacy law is available from the Office of the Australian Information Commissioner (www.oaic.gov.au).

The purpose of this Privacy Policy is to tell you what kinds of personal information we may gather or hold about you, how we may use that information, whether we disclose it to anyone, the choices you have regarding our use of that information, your ability to access or correct that information and how you may resolve any concerns you may have.

Personal Information

Personal information is information or an opinion, including information or an opinion forming part of a database, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Personal information submitted via this website

If you submit personal information via this website, your personal information will be handled in accordance with the Dealer Privacy Policy available at http://www.swanhilltoyota.com.au/privacy-policy-and-disclaimer/ (this page) and the privacy policies of the other OneToyota organisations that deal with you (if any) available at toyota.com.au/privacy. This includes using your information to send you marketing and information as outlined in the privacy policies.

What kinds of personal information do we collect and hold?

The personal information we may collect and hold varies and is dependent on the nature of our dealings with you. The information may also be necessary to ensure the statutory and legislative requirements and obligations for our industry are fulfilled.

The kinds of personal information can include but are not limited to name, address (including previous address), postal address, phone number, mobile number, drivers licence number and expiry date, gender, marital and family status, email address, employment information, financial details, your business trading details, credit card details, motor vehicle details ((including make, model, registration number, VIN, colour, options and accessories provided, trade in details, price paid, odometer readings, vehicle location, vehicle speed, vehicle diagnostic data, finance and insurance details, roadside assistance services, service history and extended warranty details)

The above information is collected and recorded about individuals who interact with us such as:

• our customers, potential customers and their representatives
• our suppliers and their representatives
• contractors and their representatives providing goods and services to us
• our employees past and present, including applicants, and
• any other person who comes into contact with us.

In most cases, if we do not collect the information we require, then we may be unable to undertake certain activities, such as providing you, or the organisation with which you are connected, with the requested information, goods and/or services.

How do we collect personal information?

Generally the personal information that we hold is collected directly from you 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 an enquiry whether it be in person, by phone, by fax, by email, by an online form or external web site
• visit our premises
• request information about us, our products or our services
• provide feedback or respond to a direct marketing campaign
• take a vehicle for a test drive or use one of our loan vehicles
• where we are required or authorised by law to do so

If you have purchased a vehicle with the Toyota 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 Toyota Link Subscription Agreement for further details.

Third Party Collection of Information

From time to time we may collect personal information from third party sources including;

• nominated representatives (e.g. spouse, accountant, and other professional advisors)
• forms you have completed on  external web sites
• Toyota Motor Corporation Australia
• vehicle registries and other government authorities (including police, local councils or insurers if, for example, a test drive vehicle is in an accident or receives a fine)
• third party suppliers who we have arranged to provide products or services to you
• publicly available sources of information
• referees whose details you  have provided to us

We will only collect your personal information from third parties if it is unreasonable or impractical to collect the necessary information directly from you or if we are otherwise permitted to do so.

How do we handle sensitive information?

The Privacy Act describes ‘sensitive information’ as information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual orientation, criminal record, and health information about an individual.

Occasionally, it may be necessary for us to collect sensitive information about you. If you or third parties provide us with sensitive information, we will as a matter of policy only use and disclose the information for the purpose for which it was provided or another directly related purpose, unless you agree otherwise, or where required by law.

Where practical and reasonable, we will only collect sensitive information with your consent.

Why do we collect personal information?

We collect, hold, use and disclose only that personal information which is necessary for us to conduct our business or for the purpose of your dealings with us.

We collect, hold and use your personal information;

• to identify you, conduct appropriate checks and communicate with you
• to enable us to understand your requirements and provide requested goods and services (including new and used vehicles, parts, accessories and any applicable warranties)
• to consider, process and record the purchase of trade-in vehicles
• to assess any request you make for the supply of goods and services by establishing your financial position and credit status (if relevant)
• to assist you to apply for credit or insurance and deal with insurance and finance issues
• confirm that you are properly licensed for the purposes of taking a test drive or using one of our loan vehicles
• process payment for goods  and services (including assisting in applications for credit where relevant)
• to coordinate delivery of vehicles
• to carry out vehicle repairs and servicing, supply parts and accessories, supply products such as lubricants and automotive fluids and maintain any applicable warranties
• to arrange for goods  and services to be supplied to you by third parties where appropriate (for example, aftermarket parts suppliers, extended warranty and roadside assistance services and financial and insurance products in respect of vehicles purchased from us; or panel beating services or windscreen replacement in respect of vehicles we are repairing)
• to collect debts
• to manage, train and develop our employees and representatives
• to set up, administer and manage our products and services
• to conduct competitions
• to administer warranty claims, including safety related product recalls
• to maintain records for accounting and administration purposes
• to develop and inform you about the goods and services that the Company considers may be of interest, unless you advises us not to do so
• to protect you and the Company from fraud
• to assess whether to provide commercial credit to you
• for business support purposes including maintenance, backup and audit
• to comply with the Company’s statutory and legal obligations, and
• to respond to any queries or complaints you may have

When do we disclose your personal information?

We may disclose your personal information to other parties where it is necessary to enable us to provide a product or service, to other third parties or where otherwise permitted by law.  We may disclose your personal information to such entities for the purposes set out above.

We may disclose your personal information to:

• nominated representatives and credit reporting bodies
• Toyota Motor Corporation Australia
• finance, insurance, extended warranty and roadside assistance providers and aftermarket parts suppliers
• debt collectors
• other companies or individuals who assist us in providing products and services to us
• professional service providers and advisors who perform functions on our or your behalf
• Government, regulatory authorities and other organisations as required or authorised by law
• providers of outsourced vehicle repair and maintenance services
• vehicle and securities registries
• financial institutions for payment processing
• referees whose details you have provided to us.

To manage and provide cost effective services, we may outsource various tasks to 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.

Organisations providing professional services to us are required to keep those dealings and personal information provided by us as confidential unless required to disclose such information by statute or law.

Overseas Disclosure

We may disclose your personal information to our third party services providers, including the Toyota Motor Corporation and Toyota Australia, for them to help us provide services to you.

Spam

We will not send you any commercial electronic messages such as SMS or emails unless permitted by the Spam Act (for example, if we have your express consent or your inferred consent to do so). Any commercial electronic message that we send will identify Swan Hill & Kerang Toyota 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 contact our Privacy Officer using the details at the end of this policy.

Job applicants and employees

The Privacy Act provides an exemption for employee records.  That is information about an individual if that information directly relates to the act or practice of a current or former employment relationship between the employer and the individual.  That exemption may apply in relation to the information held by us about our employees.

Any personal information provided to the Company 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.

How long do we 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 (such as driver’s licence numbers) as our own identifier of individuals. We will only use or disclose Identifiers in the circumstances permitted by the Privacy Act.

Marketing and Customer Satisfaction Surveys

You consent to us using your personal information for contacting you to conduct surveys and sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future.

You also consent to us sending you such information by means of mail, email, SMS, telephone calls and facsimile.  You can contact us using the contact details specified below if you do not want to be contacted for surveys and/or receive marketing information from us. If you opt out you will still receive safety related messages from us.

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. You can help by letting us know about any changes to your personal information, such as your address and phone number.

How do we manage data security?

We take reasonable steps to protect the security of your personal information by ensuring it is protected from misuse, loss, interference and from unauthorised access, modification or disclosure.

We maintain strict standards and security procedures to prevent unauthorised access to information about you whether it is in an electronic or paper format, and to ensure the correct use of this information.

Steps taken to protect personal information include:

• external and internal premises security
• restricted access to staff who need the personal  information 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
• maintaining technology products to prevent unauthorised computer access, including identifiers and passwords, security software, and firewalls.

You can access and seek correction of your personal information

Please contact our Privacy Officer using the details 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.

In accordance with the APPs, 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.

Resolving Concerns

If you have any concerns about the way your personal information is managed by us, or believe that a breach of your privacy has occurred, please let us know by contacting our Privacy Officer using the details at the end of this policy. We will respond to your concerns as soon as possible.

OneToyota Network

Swan Hill & Kerang Toyota is part of the OneToyota network of Toyota organisations in Australia (each a OneToyota organisation), comprising:

• authorised Toyota dealers in Australia;
• Toyota Motor Corporation Australia Limited;
• Toyota Finance Australia Limited;
• Aioi Nissay Dowa Insurance Company Australia Pty Ltd trading as Toyota Insurance; and
• Toyota Western Australia (comprising Prestige Motors Pty Ltd as trustee for the Prestige Toyota Unit Trust and Eastpoint Pty Ltd).

Swan Hill & Kerang Toyota and other OneToyota organisations collect and share with each other customer and guest information, including data collected from Connected Services, to provide you an integrated OneToyota guest experience, such as allowing you to be known across the network regardless of which OneToyota organisation you deal with and to provide you with products, services, information and assistance, respond to your enquiries and help keep your information up to date. Your information may be disclosed to OneToyota network service providers in Australia and overseas for these purposes.

For more information about how Toyota Motor Corporation Australia Limited and Toyota Finance Australia Limited handle your information, please see their combined Privacy Policy at www.toyota.com.au/privacy. The privacy policies of Toyota Insurance and Toyota Western Australia are each also available at that address.

OneToyota Marketing

OneToyota organisations may send you marketing to inform you about products or services, special offers, promotions and events that may be of interest to you. These marketing communications may include joint promotions with promotion partners, and may be sent to you using any contact details provided by you, such as post, phone, email or SMS.

Please note that each of the OneToyota organisations are separate organisations. If you do not wish to receive marketing from one organisation, you can let that organisation know at any time using the contact details in their privacy policy (available on their website or toyota.com.au/privacy) or using the “unsubscribe” or other opt-out function offered by the organisation.

Your consent to receive marketing from a OneToyota organisation will be deemed to be ongoing if you do not opt out when you are offered the opportunity to do so, or unless and until you advise the relevant organisation otherwise.

Personal information submitted via this website

If you submit personal information via this website, your personal information will be handled in accordance with the Dealer Privacy Policy available at www.swanhilltoyota.com.au/privacy-policy-and-disclaimer/ and the privacy policies of the other OneToyota organisations that deal with you (if any) available at toyota.com.au/privacy. This includes using your information to send you marketing and information as outlined in the privacy policies.

Enquiries

If you have any concerns or queries about our Privacy Policy, or if you would like more information about privacy-related issues, please contact us at:

The Privacy Officer

Swan Hill & Kerang Toyota

5646 Murray Valley Highway

Swan Hill  VIC  3585

Phone: 03 5033 2800

Email: info@swanhilltoyota.com.au