Protecting your Privacy
At HFH Auto Group, people’s privacy is important to us. We want our customers to have the best possible products and service so we aim to make efficient use of the personal information we collect from you. We also want our customers to have confidence that, in handling personal information, we provide an appropriate level of privacy.
1. What privacy laws apply to HFH Auto Group?
The APPs alter substantially the existing National Privacy Principles and cover:
- APP 2: Anonymity & pseudonymity – see section 3
- APP 3: Collection of solicited information – see section 4
- APP 4: Dealing with unsolicited personal information – see section 4
- APP 5: Notification of the collection of personal information – see section 4
- APP 6: Use and disclosure of personal information – see sections 5 and 6
- APP 7: Direct marketing – see section 7
- APP 8: Cross border disclosure of personal information – see section 10
- APP 9: Adoption, use or disclosure of government related identifiers – see section 15
- APP 10: Quality of personal information – see section 8
- APP 11: Security of personal information – see section 9
- APP 12: Access to personal information – see section 10
- APP 13: Correction of personal information – see section 8
From time to time HFH Auto Group contracts out the services to third parties, for example direct mailing houses, collection agencies, call centre operators, which carry out work that cannot be performed by HFH Auto Group at our premises. Personal information disclosed to these third parties facilitates the information use disclosed above.
2. What is Personal Information?
Personal information is any information about you that identifies you or by which your identity can be reasonably ascertained. APP 1 requires HFH Auto Group to take reasonable steps to implement practices, procedures and systems to protect your personal information.
- the kind of personal information HFH Auto Group collects and holds and how it is collected and held;
- the purposes for which HFH Auto Group collects, holds, uses and discloses personal information; and
- how an individual may access their personal information held by HFH Auto Group.
HFH Auto Group may hold various types of information about you, including the following:
- name, address, email, telephone number, mobile number, gender, date of birth and driver’s licence number;
- vehicle details and warranty and service details;
- any vehicle finance provided to you through HFH Auto Group;
- information collected from marketing campaigns, product research and customer surveys;
- information contained in a consumer or commercial credit report from a credit reporting body (CRB); and
- any other personal information HFH Auto Group is required to collect for identification verification purposes.
3. Anonymity & Pseudonymity
Generally, it is not possible for HFH Auto Group to transact business with you unless we are able to collect the personal information we require. Whenever it is practical or lawful to do so, however, we may offer you the opportunity to deal with us anonymously or through the use of a pseudonym, for instance in making an enquiry about interest rates or any products or services we offer.
HFH Auto Group may use technology to collect anonymous information about the use of our website, for example, when you browse our website, our service provider logs your server address, the date and time of your visit, the pages and links accessed and the type of browser used. It does not identify you personally and we only use this information for statistical purposes and to improve the content and functionality of our website, to better understand our customers and to improve our services.
4. How does HFH Auto Group collect and manage personal information?
HFH Auto Group only collects, uses or discloses personal information about you as allowed by law or where you have given consent. Personal information may be collected directly from you or via other sources such as our website, email, SMS or through a marketing campaign.
HFH Auto Group may also collect personal information about you from other sources, including a credit reference from a source mentioned in a report from a CRB when assessing your application for the provision of credit.
Whenever HFH Auto Group collects personal information, we will take reasonable steps to inform you that:
- HFH Auto Group is collecting the information;
- the purposes for which we are collecting the information;
- the organisations or types of organisations to whom HFH Auto Group may disclose the information;
- the fact that you can access your information and how you can make a complaint about a breach of the APPs; and
- how you can contact us.
If personal information concerns particular beliefs or backgrounds, such as racial background, religious beliefs, criminal record and the like, it is considered to be of a sensitive nature. HFH Auto Group does not collect sensitive information.
5. Why personal information is collected by HFH Auto Group
HFH Auto Group (including its related bodies corporate) collects personal information from its customers and suppliers, or employees or officers of its customers and suppliers, for purposes relating to the products and services it offers. Those purposes include:
- responding to enquiries regarding vehicles and vehicle sales, products and accessories and services we offer;
- receiving feedback and dealing with complaints;
- processing orders and administering accounts;
- providing customer support;
- vehicle warranties and product recalls;
- marketing and promotional activities and customer surveys; and
- applications for employment.
If we are unable to collect personal information we require, we may not be able to do business with you or the organisation with which you are connected.
Any personal information we collect will only be used for the purposes related to the products and services offered by HFH Auto Group (and its related bodies corporate) and will not be used or disclosed for other purposes.
Where possible, HFH Auto Group will collect personal information directly from you. This may take place in a number of ways, such as when you give us a written order or ask us to provide a product or service over the telephone or internet. Our website may also offer interactive facilities, such as customer enquiry or comment forms and competition entry forms, where personal information may be collected.
By providing us with your mobile telephone number and/or email address, you authorise HFH Auto Group (and its related bodies corporate) to send you, by email and/or SMS, marketing and promotional information and material and customer surveys. The messages will be accompanied by a functional unsubscribe facility.
Regardless of who provides personal information to us, it will always be handled by HFH Auto Group in accordance with the APPs.
6. Do we disclose personal information to anyone else?
In providing you with a product or service, HFH Auto Group may sometimes need to disclose your personal information to others. It is generally our policy not to disclose information to external organisations, however we may need to disclose information in the course of providing a product or service or in connection with an application by you for consumer or commercial credit. Apart from providing personal information to another organisation where you have consented to us doing so, examples of organisations to which HFH Auto Group might provide your personal information include:
- our related bodies corporate;
- other motor vehicle dealers;
- parts suppliers;
- CRB’s, insurers and financiers;
- a person outside HFH Auto Group who is contracted to us to provide a particular service on our behalf.
Some examples of the kinds of organisations with which we contract are:
- mailing houses for bulk mailing of letters and notices;
- printers for the despatch of marketing material;
- information technology service providers; and
- accountants, lawyers and other service providers.
Those contracted parties are not authorised by us to use personal information for anything other than the purpose for which we supply that information to them. However, HFH Auto Group cannot be held responsible for any misuse or unauthorised disclosure of your personal information by these third parties.
Sometimes, the law requires us to disclose personal information. For example, information may be disclosed to a court in response to a subpoena or a court order or to a government agency, such as a vehicle licensing authority or the Australian Taxation Office.
Where you have consented to us disclosing personal information, your consent may be written, verbal or implied from conduct.
7. Direct marketing
From time to time, HFH Auto Group may use personal information on our direct marketing database for postal marketing campaigns, for example informing you about our products and services or about special offers and promotions that we think may be of interest to you. We will generally give you the opportunity to express a wish not to receive direct marketing communications. You can let us know at any time if you no longer wish to receive marketing material (by contacting us via any of the means in section 13 below) and we will remove your details from our direct marketing database.
HFH Auto Group does not disclose personal information to other organisations for the purposes of allowing them to direct market their products. However, we may from time to time join with other motor vehicle dealers in joint marketing of our respective products and services to customers.
If the law requires us to provide you with information about our products or services, we will provide that information even if you have elected not to receive information about our products and services generally.
8. Access to your personal information and ensuring personal information is up-to-date
You can access most of the personal information HFH Auto Group holds about you by contacting us via any of the means set out in section 13 below. We may charge an access fee to cover the reasonable cost of retrieving the information and supplying it to you.
HFH Auto Group relies on the personal information we hold in conducting our business. Therefore, it is very important that the information we hold is accurate, complete and up-to-date. This means that, from time to time, we will ask you to tell us if there are any changes to your personal information. If you find that information we hold about you is incorrect, please contact us immediately and we will correct it.
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.
9. Security of personal information
Security of personal information is important to HFH Auto Group and we take all reasonable precautions to protect personal information from misuse, loss, unauthorised access, modification or disclosure.
Some of the ways we protect personal information include:
- external and internal premises security;
- restricting access to personal information only to staff that need it to perform their day to day functions;
- maintaining technology products to prevent unauthorised computer access or damage to electronically stored information, such as requiring identifiers and passwords, firewalls and anti-virus software; and
- maintaining physical security over paper records.
HFH Auto Group will take reasonable steps to destroy or permanently de-identify any personal information we hold when it is no longer required for any purpose for which it was collected or for which it may legitimately be used or disclosed.
10. Overseas transfer of personal information
11. Privacy and our website
The type of personal information HFH Auto Group collects through our website depends on how you make use of the site.
When visiting the HFH Auto Group website, you will not be required to provide us with any personal information, unless you request information about a product or service or respond to a competition or promotion. In that case, we will ask you to provide contact details along with other information required to respond to your request or allow you to enter the competition or promotion.
The information provided may also be retained for our business planning purposes.
12. If you send us an email
If you send an email to HFH Auto Group containing personal information, we will take reasonable steps to ensure the confidentiality of that information. The content of emails is sometimes monitored by our service provider for maintenance and fault detection purposes. We may also monitor email for legal compliance purposes.
Although we take steps to protect information sent by email, email is not a secure method of communication. If you are concerned about sending your personal information to us in this manner you may prefer to contact us by any of the other means set out below.
13. Resolving complaints and concerns
If you believe that the privacy of your personal information has been compromised or that HFH Auto Group has not dealt with your personal information in a manner that complies with law or the APPs, please let us know. You can make a complaint in writing (by email or post) to:
The Privacy Officer
HFH Auto Group
468-486 Princes Highway,
Narre Warren, VIC 3805
or by calling (03) 9707 4455 and asking for the privacy officer. We will investigate your complaint and respond as quickly as possible.
14. Third Party Websites
HFH Auto Group’s website may contain links to websites which are owned or operated by third parties independent of HFH Auto Group, including websites owned or operated by our service providers. Those websites should contain their own privacy statements and their owners or operators are responsible for informing you about their security and privacy practices.
HFH Auto Group does not collect or use Commonwealth government identifiers when dealing or interacting with you.
16. What information do we collect and hold?