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John Oxley Mitsubishi Privacy Policy

Introduction
Tuntrent Pty Ltd T/A John Oxley Motors (referred to throughout as “John Oxley Motors”) recognises that your personal information is important to you and that you are concerned with its collection, use and disclosure. Like other companies operating in Australia, John Oxley Motors is bound by the National Privacy Principles as set out in the Privacy Act 1988 (Cth) which set clear standards regarding these activities.
This policy contains information about:
• when you can deal with John Oxley Motors anonymously;
• the purposes for which John Oxley Motors collects, holds, uses and discloses personal information;
• the types of personal information that John Oxley Motors collects;
• how John Oxley Motors collects and holds personal information;
• how you may access the personal information that John Oxley Motors holds about you, and how you may seek correction of that personal information; and
• how you may complain about a breach of the Australian Privacy Principles by John Oxley Motors and how John Oxley Motors will deal with such a complaint.
Appendix A to this policy contains further information which John Oxley Motors is required to disclose under the Privacy Act 1988 (Cth) to individuals who apply at our dealership for credit from a third party credit provider
We may also use your personal information for other purposes related to those described above which would be reasonably expected by you.


When can you deal with John Oxley Motors anonymously?
Generally, you can deal with John Oxley Motors anonymously (i.e. without identifying yourself). In certain circumstances however, John Oxley Motors will ask you to provide personal information because it is required by law to do so, or because it would be impracticable to deal with you anonymously.


Why does John Oxley Motors collect, hold, use and disclose personal information?
John Oxley Motors collects, holds, uses and discloses personal information for a number of purposes connected with our business operations, which include:
• providing you with products and/or services requested;
• dealing with requests, enquiries, complaints, consumer guarantee or warranty claims, and other customer care related activities;
• marketing our products and services and providing advice on our products;
• developing and improving our products and services;
• the operation and administration of accounts that you have with us;
• payment processing;
• carrying out certain checks (for example, for our fraud or theft prevention processes, if you wish to open an account with us or obtain credit from us;
• interacting with companies or organisations with whom John Oxley Motors has a business relationship (where you work for, or otherwise represent, such an organisation);
• reconciling payments due to John Oxley Motors from suppliers in relation to goods or services provided to you by those suppliers;
• purposes relating to any third party acquisition or potential acquisition of an interest in John Oxley Motors or its assets;
• complying with our obligations under agreements with third parties (for example, under our authorised dealer arrangements and our association with consumer finance providers); and
• carrying out any activity in connection with a legal, governmental or regulatory requirement that we have to comply with, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution. In particular, John Oxley Motors is required by law to collect personal information in certain circumstances, including:

We may also use and disclose your personal information for other purposes related to those described above which would be reasonably expected by you.

Documents (including hard copy documents and electronic documents such as emails) which coincidentally contain personal information will also be retained in accordance with John Oxley Motors's normal document retention practices for accounting, legal and business purposes.

Generally, you have no obligation to provide any personal information requested by us. However, if you choose not to do so where we require this information, we are unlikely to be able to provide you with the goods and services that you want.


What personal information does John Oxley Motors collect?
The kinds of personal information we collect or which we may hold about you may include:
• your name;
• your address;
• your date of birth;
• your telephone number(s);
• your e-mail address;
• payment information;
• transaction information;
• details about your earnings (if you are buying a vehicle using a finance plan);
• information contained on identification documents (such as driving licences) and, in some specific cases, copies of such identification documents, where we require these to verify your identity;
• information on how you use our products and services;
• your Internet Protocol ("IP") address, server address, domain name and information on your browsing activity when visiting one of our websites;


How does John Oxley Motors collect and hold your personal information?
We collect personal information in a number of ways including:
• when you order goods or services from us (either from the dealership or over the telephone);
• when you set up an account with us;
• when you purchase certain products or extended warranties from us;;
• when you pay for goods by cheque;
• when you sell a second hand vehicle to us;
• when you enter competitions or promotions that we run;
• when you provide us your details for customer care purposes;
• when you browse our website (further information is set out later in this Privacy Policy);
• when you submit an enquiry using one of our website;
• when you complete surveys or provide online feedback; and
• when you publicly comment about us on social media sites (for example so that we can answer questions about our products and services).
Generally, John Oxley Motors will collect your personal information directly from you. However, John Oxley Motors also holds information, collected incidentally, concerning individuals who work for companies or organisations that have a business relationship with John Oxley Motors. Additionally, if you apply for a job with John Oxley Motors, we may collect personal information about you from any third parties that you nominate as your referees in your application.
John Oxley Motors holds personal information in a number of ways, including:
• as part of customer records and other electronic documents on which personal information is contained which are stored on our information technology systems and servers operated by third parties who provide services to us in connection with our business;


Marketing
When you create an account with us your details will be added to our marketing database to receive information relating to John Oxley Motors and our products. You may also choose to receive such information by subscribing to our marketing database via our website.

To opt-out of receiving John Oxley Motors marketing materials, you will need to unsubscribe from our marketing database. To do this, simply select the "unsubscribe" option in one of the emails that you receive from us. Please note that if you have an account with John Oxley Motors, we may still need to send you essential information about your account.


Sharing your personal information
John Oxley Motors may disclose or receive personal information or documents about you to / from:
• organisations that provide services to us in connection with our business, including customer support, payment processing, administration, hosting, research, mail and delivery, distribution, logistics, marketing, auditing, consulting, financial and legal advisory, banking and debt collection. In some cases these service providers may collect your personal information on our behalf;
• if you return a vehicle to John Oxley Motors to be repaired, our Service team and the manufacturer of the vehicle;
• law enforcement agencies to assist in the prevention, investigation and prosecution of criminal activities;
• parties involved in any third party acquisition or potential acquisition of an interest in John Oxley Motors or its assets;
• our insurers and insurance brokers; and
• to other third parties where you have specifically consented to the disclosure of information to these third parties.


Disclosure of personal information to overseas recipients
John Oxley Motors is likely to disclose the personal information that it collects and holds about you to third parties who are not in Australia.


How we deal with your personal information if you apply for a job with us
If you apply for a job with us, you may be required to provide us with certain personal information, including your name, employment and educational background, and other personal information which we may require you to provide, or which you choose to provide us, in relation to your job application.

We will hold, use and disclose that information solely for the purpose of considering your application. In particular, in considering your application, it may be necessary for us to disclose some of that information to third parties to verify the accuracy of that information. In such circumstances, we will disclose only such information as is necessary in the circumstances.

In considering your application, we may also collect personal information about you from any third parties that you nominate as your referees in your application.


Security of your personal information
We will take reasonable steps to ensure that the personal information that we hold is stored in a secure environment protected from misuse, interference and loss and any unauthorised access, modification or disclosure.

How to access, correct and update your personal information
Upon your request, John Oxley Motors will provide access to your personal information that we hold (except in certain circumstances set out in the Privacy Act 1988 (Cth)). John Oxley Motors will, of course, require some proof of your identify before providing information to you.

You may also request us to correct the personal information that John Oxley Motors holds about you. If you do so and we are satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, John Oxley Motors will take such steps as are reasonable in the circumstances to correct your personal information to ensure that, having regarding to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.

To request access to the personal information that John Oxley Motors holds about you, or to update or correct that personal information, please send a written request to The Privacy Officer, John Oxley Motors Limited, either by email to privacy@johnoxley.com.au

How to make a complaint

If you are concerned that the way John Oxley Motors collects, holds, uses or discloses your personal information may be in breach of the Australian Privacy Principles, please send written details of your complaint to The Privacy Officer, John Oxley Motors, either by email to privacy@johnoxley.com.au


How John Oxley Motors will handle complaints
After receiving a complaint, we will consider whether we need any further information from you to properly consider and investigate the complaint, and may request such information from you. We will then:
• conduct internal discussions with the relevant business units involved in the collection, holding, use or disclosure of your personal information which is the subject of your complaint, and evaluate whether we believe that such collection, holding, use or disclosure of your personal information was in breach of the Australian Privacy Principles; and
• notify you of the results of our investigation of your complaint.
If the conclusion of our investigation is that our collection, holding, use or disclosure of your personal information was in breach of the Australian Privacy Principles, we will take steps to remedy the breach as soon as reasonably practicable.

We will endeavour to notify you of the results of our investigation of your complaint within 30 days of receiving your complaint. However, if your complaint involves complex matters or requires extensive investigation and consultation, it may not be possible to respond within this timeframe.
If you are not satisfied with our response to your complaint you are entitled under the Privacy Act 1988 (Cth) to make a complaint to the Office of the Australian Information Commissioner. Information about how to make a complaint is available from the Office of the Australian Information Commissioner's website (www.oaic.gov.au).


Additional information for users of our websites
If you visit www.johnoxley.com.au or any other John Oxley Motors websites (the "Websites") to read, browse or download information, our system may record information such as the date and time of your visit to the Website, the pages accessed and any information downloaded. This information is used (i) for statistical and reporting purposes; (ii) for website administration, security and maintenance purposes; and (iii) to direct you to material on our Websites that we believe will be of interest to you.

Like many websites, our Website may use "cookies" from time to time. Cookies are small text files that we transfer to your computer's hard drive through your web browser to enable our systems to recognise your browser and your log-in status. Cookies may also be used to record non-personal information such as the date, time or duration of your visit, or the pages accessed, for website administration, statistical and maintenance purposes. Any such information will be aggregated and not linked to particular individuals. The default settings of browsers like Internet Explorer usually allow cookies, but users can easily erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of the Website may not function fully for users that disallow cookies.

While we take great care to protect your personal information on our Website and use state-of-the-art data transmission encryption, unfortunately no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information that you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us. Once we receive your transmission, we use our best efforts to ensure its security in our possession.

The Websites may contain links/ plug-ins to other sites. We are not responsible for content of, or the privacy practices or policies of, those sites. 


Exemptions
John Oxley Motors sometimes handles personal information relying on exemptions under the Privacy Act 1988 (Cth), for example in relation to (i) employee records; (ii) related bodies corporate; (iii) provision of services to State or Territory authorities; and (iv) operations outside Australia relating to personal information of non-Australians.

Any permitted handling of personal information under such exemptions will take priority over this Privacy Policy to the extent of any inconsistency.


Privacy Queries
If you have any queries or concerns, further information can be obtained by contacting our Privacy Officer by email privacy@johnoxley.com.au or by post to The Privacy Officer, John Oxley Motors, PO Box 630 Port Macquarie, 2444.

John Oxley Motors ACN 002 056 500
Version 2 28th October 2016


Appendix A - Further information for individuals who apply at our dealership for credit from a third party credit provider
Background
As part of John Oxley Motors's arrangements with third party credit providers (such as St George Finance, Volkswagen Financial Services etc.):
• customers may apply at the dealership for credit provided by third party credit providers; and
• John Oxley Motors may assist in the processing of such applications.

This Appendix A contains certain information which John Oxley Motors is required under the Privacy Act 1988 (Cth) to disclose to individuals who apply at the dealership for credit from a third party credit provider. In this Appendix A, these individuals are referred to as Third Party Credit Applicants.

Unless you are a Third Party Credit Applicant, the information in this Appendix A will not be relevant to you.


What kinds of credit-related information does John Oxley Motors collect and hold about Third Party Credit Applicants?
John Oxley Motors may collect (and hold) certain personal information contained in the application documentation completed by Third Party Credit Applicants when they apply at the dealership for credit from a third party credit provider, including his or her:
• full name;
• date of birth;
• sex;
• current address (as shown on his or her driver's licence);
• employer; and
• driver's licence number.
John Oxley Motors will also collect (and hold) certain information contained in the application documentation completed by Third Party Credit Applicants about the credit applied for by Third Party Credit Applicants, including:
• the name of the third party credit provider;
• the type of credit applied for;
• the day on which the credit is applied for (and entered into);
• the terms and conditions of the credit applied for (including in relation to repayment);
• the maximum amount of credit available under the consumer credit applied for; and
• the expiry date of the credit.
The information described in the preceding 2 paragraphs is collectively referred to as Application Documentation Information.


Why does John Oxley Motors collect, hold, use and disclose Application Documentation Information?

John Oxley Motors collects, holds, uses and discloses Application Documentation Information for the purposes of:
• submitting the application documentation completed by Third Party Credit Applicants to the relevant third party credit providers; and
• administering its arrangements with those third party credit providers.
Hard copies of the application documentation signed by Third Party Credit Applicants (which will contain Application Documentation Information) will also be retained in accordance with John Oxley Motors's normal document retention practices for legal and business purposes.
How does John Oxley Motors hold Application Documentation Information?
John Oxley Motors holds Application Documentation Information by securely storing the hard copy application documentation signed by Third Party Credit Applicants, at our premises.

Is John Oxley Motors likely to disclose Application Documentation Information to recipients who are not subject to Australian privacy laws? John Oxley Motors is not likely to disclose Application Documentation Information to recipients who are not subject to Australian privacy laws.


How to correct and update your Application Documentation Information
You may also request us to correct the Application Documentation Information that John Oxley Motors holds about you. If you do so and we are satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, John Oxley Motors will take such steps as are reasonable in the circumstances to correct your Application Documentation Information to ensure that, having regarding to the purpose for which it is held, it is accurate, up-to-date, complete, relevant and not misleading.

To request John Oxley Motors to correct or update the Application Documentation Information that it holds about you, please send a written request to The Privacy Officer, John Oxley Motors, either by email to privacy@johnoxley.com.au or by post to PO Box 630, Port Macquarie NSW 2444.


How to make a complaint
If you are concerned that the way John Oxley Motors collects, holds, uses or discloses your Application Documentation Information may be in breach of Division 3 of Part IIIA of the Privacy Act 1988 (Cth) or the registered Credit Reporting Privacy Code, please send written details of your complaint to The Privacy Officer, John Oxley Motors, either by email to privacy@johnoxley.com.au or by post to PO Box 630, Port Macquarie NSW 2444.


How John Oxley Motors will handle complaints
After receiving a complaint, we will consider whether we need any further information from you to properly consider and investigate the complaint, and may request such information from you. We will then:
• conduct internal discussions with the relevant department involved in the collection, holding, use or disclosure of your Application Documentation Information which is the subject of your complaint, and evaluate whether we believe that such collection, holding, use or disclosure of your Application Documentation Information was in breach of Division 3 of Part IIIA of the Privacy Act 1988 (Cth) or the registered Credit Reporting Privacy Code; and
• notify you of the results of our investigation of your complaint.
If the conclusion of our investigation is that our collection, holding, use or disclosure of your Application Documentation Information was in breach of Division 3 of Part IIIA of the Privacy Act 1988 (Cth) or the registered Credit Reporting Privacy Code, we will take steps to remedy the breach as soon as reasonably practicable.

We will endeavour to notify you of the results of our investigation of your complaint within 30 days of receiving your complaint. However, if your complaint involves complex matters or requires extensive investigation and consultation, it may not be possible to respond within this timeframe. In these circumstances, we will seek your agreement to a longer period for us to respond to your complaint.

If you are not satisfied with our response to your complaint you are entitled under Part V of the Privacy Act 1988 (Cth) to make a complaint to the Office of the Australian Information Commissioner. Information about how to make a complaint is available from the Office of the Australian Information Commissioner's website (www.oaic.gov.au)