Provider & data privacy.
LSH Auto is an organisation and "APP Entity" for the purposes of the Privacy Act and is subject to the Australian Privacy Principles. No general exemptions under the Privacy Act apply to us or to any of our acts and practices.
2. How we collect, hold and use personal information
We will collect your personal information directly from you unless it is unreasonable or impractical to do so, and will limit the personal information we collect to that which is reasonably necessary for our functions or activities.
So that we can provide you with our services, we collect a range of personal information, including:
• Information you provide to us when accessing or using our Services. We collect information you provide to us, including, but not limited to:
- Your name, email address, telephone number, occupation, vehicle registration details, driver's lincence details, financial information, and current and past vehicle information. The specific information we collect will depend on the circumstances of our interaction with you, but we often collect some or all of these kinds of information when you access or use our Services, participate in our promotions or competitions, or when you visit us to test drive or purchase a vehicle or arrange to have your vehicle serviced, repaired, or if you apply for a position or employment with us;
- your credit card details, bank account information and/ or billing information if required to process a transaction with you, for example if you purchase products or services from us. Credit card details are not stored in any form by us or on any internal or external databases that are accessible to us; and
- any other information you choose to provide to us . For example, when you communicate with us (whether by telephone, email or SMS) we will collect your contact details and any other information you volunteer to us.
• Information about your use of our Website. We also collect information when you use or access our Website. Our collection and use of this information is discussed below in the section headed "Website Usage, Tracking Information and Cookies".
We do not generally collect (or, if it is provided to us, retain) any "sensitive information" (as that term is defined in the Privacy Act) about you.
If you fail to provide personal information requested by us, there may be a range of of consequences, for example we may not be able to respond to your enquiry or otherwise provide you with our Services. There will not usually be Australian laws or court/ tribunal orders which require or authorise us to collect your personal information.
We may in some circumstances, collect personal information about you from third parties, in which case we will take reasonable steps to notify you of that information and the circumstances of its collection. Some specific circumstances in which we collect personal information from other sources may include collection from:
• other members of LSH Auto's corporate group. The Privacy Act allows the sharing of certain personal information within our corporate group (ie the collection of personal information from a related body corporate);
• customers or other individuals who provide us with information about you, such as joint owners, family members or referees;
• third party suppliers such as roadside assistance service providers;
• publicly-available sources such as data aggregators, public databases and other commercial providers, and information that you or others may post online, eg on social media platforms. This may include information such as your name, demographic, interests and other publically-available data. We (or our service provider on our behalf) may combine this information with other information including information we collect directly from you. We may also associate information about your use of our digital services over time with your personal information, eg where on any occasion you have logged in, followed a link sent to you by email or where we have otherwise been able to identify you;
•Austroads Ltd's National Exchange of Vehicle and Driver Information System if we are conducting a recall; and/or
3. Use of Information
We will generally only use your personal information for the purpose of which we collected it, and for related purposes we consider would be within your reasonable expectations. Purposes for which we may use your personal information include to:
• provide the products and services requested, respond to your enquiries, send you information that you request, or otherwise achieve the purpose for which the information was submitted to us;
• facilitate the sale of our products or services, or the products and services of third parties;
• set-up and configure customer accounts, and identify our customers, potential customers and people acting on their behalf; • record and maintain user details and profile information;
• contact you to invite you to events (such as a new program we are launching) or inform you about new Services we provide;
• deliver marketing materials to you regarding new Services and offers we believe may be of interest to you, and conduct market research, marketing or promotional activities;
• improve our Services, for example conducting customer satisfaction surveys following the purchase of a vehicle from us or following vehicle servicing;
• provide customer support including responding to your concerns and resolving disputes
• help us plan for the future by using some information for administrative purposes such as statistical information (with such statistical information usually being un-identified);
• compare information provided by you for accuracy and verify it with third parties; and
• engage in other activities where required or permitted by law.
Where we propose to use your personal information for another purpose other than as outlined above, we will, generally seek your permission (unless we are required or permitted by law to do so without seeking consent).
4. Storage and Security
We will take reasonable steps to keep the information we hold about you secure and protect your personal information from misuse, interference and loss as well as unauthorised access, modification or disclosure.
Information stored by us is protected by our security access policies and procedures. For example, personal information we collect and store on our computer network is stored on secure servers and is only accessible by those persons who need access to the information to carry out their business functions. We also maintain physical security measures to protect tangible (hard-copy) records containing personal information.
We undertake regular monitoring of our practices, procedures and systems to ensure the effectiveness our security policies and identify and implement improvements where appropriate. However, no method of transmission or electronic storage is completely secure, and we cannot garantee the secuirty of data, particularly if it is transmitted through services such as the internet or third-party platforms (eg, email or social media platforms). You transfer your personal information to us at your own risk.
If your information is disclosed to third-party service providers, we will ordinarily enter into arrangements which require them to maintain the secuirty of your information.
We will endeavour to destroy or de-identify your personal information as soon as it is no longer required by us (where permitted by law). When we dispose of personal information, we endeavour to ensure that it is destroyed or permanently de-identified in a secure manner.
5. Disclosure of Personal Information
We will generally only disclose your personal information for the purpose of which we collected it, and for related purposes we consider would be within your reasonable expectations. We may disclose your personal information to others, including but not limited to:
• other members of LSH Auto's corporate group. The Privacy Act allows the sharing of certain personal information within our corporate group (ie the disclosure of personal information to a related body corporate);
• third party suppliers such as the vehicle manufacturer, Mercedes-Benz Australia / Pacific Pty Ltd, where necessary for us to provide products to you and for related purposes such as administration of your vehicle manufacturer's warranty;
• third party providers of financial and credit services, such as Mercedes-Benz Financial Services Australia Pty Ltd, where you apply for finance offered by a provider in connection with the purchase of a vehicle from us;
• Service providers contracted by us, including information technology service providers, printers and distributors of marketing materials, creditors, banks, financiers, credit providers, insurers and external business advisors (such as auditors and lawyers);
• third parties as necessary in order to detect and prevent fraud and protect the rights, property and safety of our business, you and others; and
• third parties as necessary in order to enforce our policies and agreements.
We may disclose your personal information to overseas recipients if it is required to fulfil the purpose for which we collected it, in which case we take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles. However, we are not generally likely to disclose personal information to overseas recipients other than our parent company located in Hong Kong SAR in order to comply with reporting and other corporate obligations.
6. Access to, and correction of Personal Information
You may contact us to request access to or correction of the personal information about you that we hold, in which case we will respond to your request within a reasonable period after the request is made. We may refuse your request to allow access or to amend your personal information (or only partially comply with such a request) if we are legally required or entitled to do so. In that case, we will provide you with written reasons for refusal (unless it is unreasonable to do so) together with information about the options available to complain about the refusal.
We may require you to pay certain costs in order to access your personal information held by us. We will advise the amount payable (if any) once we have assessed your application for access. We will not however charge a fee for you to lodge a request for access to or correction of your personal information.
If you lodge a request for access to your personal information, we request that you identify, as clearly as possible , the types of information requested. We may fulfil that request in any range of ways (for example, by supplying you with a copy of that personal information or providing you with the opportunity to inspect our records). We may require you to comply with certain procedures before we allow access to or amendment of your personal information to ensure the integrity and security of of information that we hold. Depending on the nature of your request, this may include verifying your identity to our satisfaction.
We will take reasonable steps to ensure that the personal information that we collect, use and/or disclose is accurate, up-to-date and complete and relevant. If we are satisfied that any personal information we have about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will amend our records accordingly.
Please notify us if your personal details change so that we may keep our records current.
7. Website Usage, Tracking Information and Cookies
We collect limited information about people who use our Services so that we can track the use of those resources, maintain and improve our Services, and understand how our users navigate through and use our Services. We do not use these technologies for tracking of any information about your use of other websites or services. Information we collect may include:
• details about you and your device, such as your IP address, top level domain names, location or device information, and any other information provided by your mobile device, if you access or use our Website via a mobile device or application. If you do not want us to collect your location information you may be able to disable the GPS or location-tracking function of your device;
• data collected using any intergrated plugins on our Website. We use both first-party and third-party cookies and similar tracking technologies on our Website. A cookie is a small data file that is stored on your device and collects information, such as your IP address or information about your use of or activities on our Website. Further information about this is detailed below;
• data relating to your use of our Website, which may include your IP address, data and time of your access or use of our Website, page views and documents downloaded, the referring URLs, and any other information about your activities on our Website; and/or
• search terms, interactions with other users, and any other activities on our Website.
(Collectively, Usage Information)
• Phone calls to the Dealership via 07 3186 0567 are tracked and recorded for training purposes.
Unless you have registered for an account with us, we will not link Usage Information to your personal information such as your user name. If you register for an account with us, Usage Information will be aggregated with that of other unregistered users and will not be associated with an identifiable person.
You may decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of our Websites, products and services. You can refer to the documentation for your browser or installed applications for instructionson blocking, disabling and deleting cookies.
8. Google Analytics
By using our websites you consent to the storing and accessing of cookies or other information on your device for the purpose of Google Analytics, unless you have opted-out. To opt-out you may be able to install the Google Analytics Opt-out Browser Add-on. You may also be able to opt-out of Google Analytics Advertising Features, such as interest-based advertising served by Google on its products or across the Google Display Network through the Google Ads Settings or other available means (for example, the Newtwork Advertising Initiative opt out). The Google opt-outs may not stop all advertising. Google may still serve advertising that is not interest-based, and you may still receive interest based advertising that is not served by Google.
9. Facebook Pixel
Our websites may use the Facebook Pixel (Pixel), which is a website feature which allows us the receive information on user activity on our website from users that have been redirected to our website by clicking on our Facebook advertisments. This enables us to measure the effectiveness of our Facebook advertisments for statistical and market research purposes. The Pixel does not collect and personal information of individual users. The data collected by the Pixel is stored and processed by Facebook, which has ultimate control of the information gathered through the Pixel. Facebook may link the information collected by the Pixel to your Facebook account and also use it for its own promotional purposes in accordance with Facebook's Data Usage Policy: https://www.facebook.com/about/privacy/. You may be able to opt-out of our use of Pixel through the settings of your Facebook account. By using our website you consent to our use of the Pixel, unless you have opted-out.
10. Adobe Analytics
Our websites may use Adobe Analytics tools, including Analytics Workspace. These tools collect information about our website visitors and their experience on our website. We use this information to help us optimise our website design and usability to meet the needs of our website visitors. Adobe Analytics may collect certain information, such as your IP address, the webpage that led you to our website, the search term that you entered into the search engine which led you to our website, and your general use of our website. We understand that this information is collected and stored on Adobe's data collection servers. We may access this information for marketing and and other purposes. We understand that Adobe Analytics does not collect your personal information. For more information about Adobe Analytics, and how it collects and processes information, click here:
You may be able to limit the information collected by Adobe Analytics by managing your browser settings regarding cookies.
11. Third-Party Links
Our Services may include links to other websites whose operators' privacy practices may differ from ours. If you provide your personal information to any of those sites, your information will be governed by thos operators' privacy policies.
12. Changes and Updates
If you believe that a breach of your privacy has occured, we encourage you to contact us to discuss your concerns. Our contact details can be found below.
Your complaint will be considered and dealt with by our LSH Auto Australia Group Privacy Officer. The Privacy Officer may escalate the complaint internally within our organisation if the matter is serious or if necessary to resolve it. We will treat your complaint confidentially and, after investigating your complaint, may contact you to discuss the ways in which we can remedy the situation.
Please allow us reasonable time to respond to your complaint. If you are not satisfied with our proposed resolution, you may make a complaint to the Office of the Australian Information Commissioner, whoes contact details can be found at: www.oaic.gov.au.
14. Further Information
You may contact us if you require further information about the ways we manage your personal information.
Joanna Zhou | Group Privacy Officer
LSH Auto Australia 824 Ann Street
Fortitude Valley, QLD 4006
Tel: (+61) 7 3251 6666
© LSH Auto (Brisbane) Pty Ltd.
MBAuP Privacy Statement
• how you can deal with us anonymously;
• the kinds of sensitive information we collect;
• how we collect your personal information;
• the purpose by which and how we collect, use and disclosure your personal information;
• cross border disclosure;
• when we will use your personal information for direct marketing;
• how we keep your information secure;
• how to access, update or correct your personal information; and
• how you can make a privacy complaint.
Most of our authorised dealer network is independently owned and operated, and may have privacy policies which differ from ours (except in the case of wholly owned retail outlets, in which case, this policy applies). Our independent authorised dealers are responsible for their own respective privacy policies and privacy related processes. If you have any privacy concerns relating to an independent dealer then please contact the relevant dealer directly.
1. THE COLLECTION OF PERSONAL INFORMATION
1.1 Kinds of information we collect and hold
We collect information that is reasonably necessary for or directly related to one or more of our functions and activities. The types of personal information we collect include but are not limited to your:
- occupation and employment details;
- contact details;
- address details;
- registration and driver’s licence details;
- credit card and bank account details;
- other financial information;
- current and past vehicle information and details;
- cookies and website tracking;
- location through anti-theft vehicle tracking technology in loan and demonstrator vehicles;
- voice and image;
- educational qualifications and resume;
- personal interests.
Where appropriate, we provide you with the option of remaining anonymous when entering into transactions with us, unless such anonymity would be considered unlawful or impracticable. If you elect not to provide us with your personal information, we may not be able to do business with you or consider you for recruitment opportunities.
Generally we do not collect sensitive information. However, we may collect sensitive information about you (for example, health information and criminal record checks if you are applying for a job with us), if we have your express consent or if the collection is required or authorised by law.
1.2 How we collect your personal information
We take steps to ensure that we collect personal information by lawful means, and obtain your personal information in various ways, including but not limited to:• when you contact or correspond with us;
• when you phone our customer support and assistance centres or require support;
• when you attend one of our premises;
• when you visit an authorised dealership to test drive or purchase a vehicle or have your vehicle serviced or repaired. Vehicles that you test drive or loan from us or one of our wholly owned dealerships may also be fitted with anti-theft tracking technology and in this respect we may track your location;
• if you order a product or service from us;
• if you apply to be a dealer or through dealer communications;
from third party roadside assistance service providers;
• via our websites if you choose to supply the information to us by entering your information into the interactive sections on our websites (for example, enquiry forms, message boards, chat, profile pages, blogs, social networking features and the like). Please be aware that any information you post or disclose on these websites may be available to other site visitors and the general public (depending on the privacy settings you have in place);
• when you attend a (product) focus group, review a product or complete a survey;
• via social media;
• from publicly available sources (including but not limited to commercially available sources such as data aggregators and public databases) and also information that you or others may post about yourself online e.g. social media pages. This information may include things like name, demographic, interests and other publically observed data. We (or our service provider on our behalf) may combine this information from information with other information including information we collect directly from you. We may also associate information about your use of our digital services over time with your personal information, e.g. where on any occasion you have logged in, followed a link sent to you by email or where we have otherwise been able to identify you;
• from third party service providers;
• when you apply for work with us and during reference checks;
• from other related or Daimler Group companies;
• from Austroads Ltd’s National Exchange of Vehicle and Driver Information Systems if we are conducting a recall; and/or
• from government bodies, enforcement and regulatory authorities.
2. PURPOSE OF COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
2.1 How we use personal information
Primarily we collect personal information so we can provide you with the best possible products and services that we and our authorised dealerships have to offer, to create a more personalised experience for you, and in order to comply with our legal, regulatory, industry or workplace requirements. More specific purposes include but are not limited to:
• any purpose which we inform you about when we collect your personal information or to which you have provided your consent;
• any purpose relating to buying, selling, repairing and loaning vehicles and parts;
• if you wish to own or already own a franchise of our products and/or services;
• any related purpose which would be reasonably necessary or directly related to one or more of our functions or activities;
• responding to enquiries in relation to products we sell and services we offer;
• providing support to our customers and authorised dealer network;
• customer assistance, care, contact and information;
• fulfilling and processing orders and administering accounts;
• roadside assistance, vehicle warranty, product issues, service measures and recalls;
• marketing, event and promotional activities;
• informing you of special events or offers;
• market research, customer surveys, customer analysis and product development;
• accounting, billing or other internal administrative purpose;
• recruitment purposes;
• to protect our interests by registering a security interest on the Personal Property Securities Register;
• checking against sanctions lists;
• to comply with industry, legal and regulatory requirements; and/or
• where permitted or required by law, a court or tribunal.
During the course of our day to day business, we may disclose your personal information to third parties outside our organisation, including but not limited to:• those that you have consented we disclose your personal information to, either impliedly by your conduct, verbally or in writing;
• our authorised dealer network;
• contracted service providers including but not limited to advertising and marketing agencies, financiers, insurers, mailing houses, printers, organisations that assist us to conduct promotions or market research, payroll service providers, recruitment agencies, debt collectors, data analysts, IT service providers, roadside assistance providers, database storage and service providers, cloud service providers and professional advisors;
• to other members that are part of, related to or associated with the Daimler Group (many of whom are based overseas see 2.3 below);
• to related companies for example, Mercedes-Benz Financial Services Australia Pty Ltd that we share corporate services with for example, information technology and human resources;
• for the purposes of facilitating or implementing a sale or transfer of all or part of our assets or business; and/or
• as required by an enforcement authority, regulator, law, court or tribunal.
2.3 Cross border disclosure
In the ordinary course of our day to day business activities and those of our related and associated entities and service providers, your personal information may be transferred, accessed, processed and/or stored in various countries within Asia, Africa, Europe and North America and other parts of Australasia.
Though for the most part, this will mean Germany, Singapore, the United Kingdom, India and Japan.Where we arrange for work or services to be undertaken on our behalf, that work is undertaken under conditions of confidentiality and may result in your personal information being transferred, accessed, processed and/or stored (for example, on clouds or servers) in various countries for the purpose of service delivery to us or you.
Unless an exception applies in the Privacy Act, prior to disclosing personal information to overseas recipients we will take reasonable steps in the circumstances to ensure that the overseas recipient adheres to the APPs.
2.4 Direct marketing
Direct marketing involves us communicating directly with you to promote the sale of our goods and services. This can be achieved by an array of methods including for example, by mail, telephone, e-mail or SMS/IM/MMS and potentially by third parties on our behalf. We will obtain your consent prior to using or disclosing your personal information for direct marketing purposes.
We do not actively market to children or knowingly collect personal information about children without parental consent. Whilst we do take steps to ensure that children’s privacy and rights are not compromised, it is ultimately the responsibility of parents to monitor their children’s internet usage.
2.4.1 Electronic communications
Where we electronically communicate with you (e.g. by instant messaging, SMS/IM/MMS, and other mobile phone messaging (but excluding voice to voice communications)) for the purpose(s) mentioned above, we comply with the Spam Act 2003 (Cth) as amended from time to time. We take steps to ensure that our electronic communications meet the following conditions, they:
(a) will only be sent with your consent, which you either provide expressly, or in very limited circumstances, that consent is inferred by your conduct or an existing ongoing business relationship;
(b) contain accurate information about us and how to contact us; and
(c) contain a functional unsubscribe facility to allow you to opt out of receiving electronic messages from us in the future.
2.4.2 Do Not Call Register Act 2006 (Cth)
The Do Not Call Register Act 2006 (Cth) allows telephone numbers to be registered if they are used primarily for domestic or private purposes in order to allow you to opt out of receiving most telemarketing calls or marketing faxes. If you have registered your private or domestic number on the register, then we will not contact you for telemarketing purposes for example, offering to sell you goods or services except if you have expressly opted in to receive direct marketing phone calls from us of which you can opt out of at any time.
However, we will still contact you for purposes that are not telemarketing purposes, including but not limited to the following:• product recall, issue and fault rectification calls;
• appointment reminder and rescheduling calls;
• calls relating to payments;
• calls relating to a contract or the subject matter of contract we have with you; and
• solicited calls.
2.4.3 Opting out
If you do not wish to receive direct marketing, electronic communications or telephone calls from us for direct marketing purposes, you can opt out at any time. Please let us know by contacting us on +61 3 9566 9266. When you opt out, we will stop sending the material until such time as you change your preferences.
If you elect not to receive any direct marketing material from us, you are likely to miss out on special product and service promotions, invitations to events, publications and other items that fall into this category.
3. SECURITY OF PERSONAL INFORMATION
3.1 Integrity and quality of personal information
We take reasonable care to ensure that personal information we use, store and subsequently destroy/delete (where relevant) meets certain quality requirements, in that the personal information is accurate, up to date and complete.
3.2 Security of personal information
While care is taken to protect your personal information, unfortunately no data transmission over the internet is guaranteed as being 100% secure. Accordingly, we cannot guarantee the security of any information you send to us or receive from us online. That is particularly true for information you send to us via email as we have no way of protecting the information until it reaches us. Once we receive your personal information, we are required to protect it in accordance with the Privacy Act.
MBAuP follows the Daimler global policies, guidelines and standards to secure your information. We continually train and remind our staff of the importance of keeping information safe and secure.
We have adopted active security measures to ensure that your personal information is kept safe from misuse, interference, loss, unauthorised access, disclosure and modification, such as:
(a) System security: Our application systems are password protected and can be accessed only by people authorised to do so. Our policies require us to encrypt confidential information, for instance, when you provide information to us using our website or when you send information from your computer to us. Security is inbuilt into the design and operations of our systems through the use of firewalls, ethical hacking and virus scanning tools.
(b) Physical security: Our premises are protected against unauthorised access by way of access card for entry, cameras, alarms and security services.
(c) Data retention: If personal information is no longer required for the purpose for which we are permitted to use, disclose or legally retain it, then we will permanently remove from a record any information by which an individual may be identified in order to prevent future re-identification from the data available. We retain information as long as needed to comply with the law or our own corporate policies and procedures.
Whilst we seek to keep your personal information secure, errors may occur from time to time and we will act quickly to investigate them and implement measures to avoid them from happening again (where possible).
We will at no time sell, rent or trade your personal information to or with any other unrelated entity.
4. ACCESS, CORRECTION, COMPLAINTS AND ENQUIRIES
We take reasonable steps to ensure that information we collect, hold or disclose about you is accurate, complete and up to date.
4.1 Access to information we hold about you
At any time you can request access to information we hold about you. We aim to respond to your request within 30 days. We may charge a reasonable fee for information requests.
Whilst we are obliged to provide you with access to your information, there are exceptions and those are outlined in the Privacy Act. If one of the exceptions applies to your access request, we will (if reasonable in the circumstances) work with you and attempt to provide you with access in a way to meet both of our needs. If it is reasonable in the circumstances, we will also notify you in writing if we have determined to refuse access to your personal information due to one of the exceptions listed above and the reasons for that refusal.
4.2 Correction of information we hold about you
We also encourage you to actively engage with us and let us know when your details change or if your personal information needs correction or updating via our contact information provided below.
4.3 Complaints and enquiries
If you are not happy with the way we have handled your personal information or believe that we have breached the Privacy Act or APPs then please contact us and we will try our best to resolve the matter with you. For security reasons, we request that complaints, requests for access to or correction of personal information or any enquiries or questions concerning privacy matters be put in writing and either e-mailed or posted to:
The Privacy Officer
Mercedes-Benz Australia/Pacific Pty Ltd
44 Lexia Place
By phone: 1300 300 896
By email: firstname.lastname@example.org
We may also require proof of your identity.
For information about privacy generally, or if your concerns are not resolved to your satisfaction, please contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.
5. INFORMATION RELATING TO PROSPECTIVE, CURRENT AND FORMER EMPLOYEES
If an employee has any questions or requests relating to their employee records, then the employee should contact MBAuP’s human resources department.
Last updated April 2016©
Copyright Mercedes-Benz Australia/Pacific