Version date: January 2016
1.1 Western Region Automotive Proprietary Limited ABN 72 112 718 420 trading as Sinclair Peugeot (“Sinclair Peugeot”, “we”, “our” and “us”) is committed to responsible privacy practices and to complying with the Privacy Principles contained in the Privacy Act 1988 (Cth) (“Privacy Act”). Where applicable, Sinclair Peugeot will handle personal information relying on the related bodies corporate exemption and the employee records exemption in the Privacy Act and any other applicable exemptions in the Privacy Act or other legislation.
2. What is personal information?
3. What types of personal information does Sinclair Ford collect?
3.1 The types of personal information Sinclair Peugeot collects from you depend on the circumstances in which the information is collected.
3.2 Sinclair Peugeot may collect contact details including your name, address, email address and phone and fax numbers.
3.3 Where relevant, Sinclair Peugeot may also collect your driver’s licence and registration details, date of birth or age group, occupation, gender, information about your vehicle (including its number plate and vehicle identification number), answers you provide to questions we ask and other information in relation to your dealings with Sinclair Peugeot (such as types of vehicle purchased and replaced and repair/service history).
3.4 If you are an individual contractor to Sinclair Peugeot, in addition to the information referred to in section 3.3 we may collect information relevant to your engagement with Sinclair Peugeot including qualifications, length of engagement, resume, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of Sinclair Peugeot equipment (e.g. phones, computers and vehicles). A reference to an individual contractor in this document includes those individuals who perform work for Sinclair Peugeot under a “purchased service” arrangement.
3.5 When using the Sinclair Peugeot website, we may collect web site usage information such as the IP address you are using, the name of your Internet service provider, your browser version, the web site that referred you to us and the next website you go to, the pages you request, the date and time of those requests and the country you are in. Except where you provide it to us via the website, we do not collect personal information such as your name, mailing address, email address or phone number when you are browsing our website.
3.7 If you do provide sensitive information to us for any reason (for example, if you provide us with information about a disability you have), you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.
3.8 Occasionally, sensitive information in relation to an individual’s membership of a trade or similar association may be provided to us but we do not actively seek this information. We will only use and disclose that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.
3.9 In addition to the types of personal information identified above, Sinclair Peugeot may collect personal information as otherwise permitted or required by law.
4. How do we collect your personal information?
4.1 Sinclair Peugeot collects personal information in a number of ways. The most common ways we collect your personal information are:- directly from which you purchase Sinclair Peugeot related goods or services;
5. For what purposes do we collect, use and disclose your personal information?
5.1 The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.
5.2 We may use or disclose your personal information:
5.3 In general we collect, use and disclose your personal information so that we can do business together and for purposes connected with our business operations.
5.4 Some of the specific purposes for which we collect, use and disclose personal information are as follows:- to facilitate your request for a brochure or test drive, to add you to a mailing list or to respond if you request information (including via the Sinclair Peugeot website or via an email you send to us);
5.5 We may also use and disclose your personal information for the purpose of direct marketing to you where:- you have consented to us doing so; or
6. What happens if you don't provide personal information?
6.1 Generally, you have no obligation to provide any personal information requested by us. However, if you choose to withhold requested personal information, we may not be able to provide you with the products and services that depend on the collection of that information.
6.2 As an example, if we did not collect personal information about your new vehicle purchase, we would be unable to notify you directly of a product recall affecting your vehicle.
7. To whom do we disclose personal information?
7.2 This may include disclosing your personal information to the following types of third parties:- our related companies;
7.3 Where we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the Privacy Principles under the Privacy Act, e.g. by (where commercially practical) including suitable privacy and confidentiality clauses in our agreement with a third party service provider to which we disclose your personal information.
7.4 If you post information to certain public parts of our website or to our social media pages, you acknowledge that such information may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.
8. Does personal information leave Australia?
8.1 Some of the third parties to whom we disclose personal information may be located outside Australia. For example, we may disclose personal information to our related companies overseas and to our overseas service providers.
8.2 The countries in which these third parties are located will depend on the circumstances. In the ordinary course of business we commonly disclose personal information to parties located in the United States, India, China, Singapore (where our Peugeot group data and business centres are located) and to the United Kingdom. Except where an exception applies under the Privacy Act, we will take reasonable steps to ensure that such overseas recipients do not breach the Privacy Principles in the Privacy Act in relation to such information.
9. How do we protect personal information?
9.2 Your personal information will not be “sold” by Sinclair Peugeot to any other organisation for that organisation's unrelated independent use.
10. What about information you provide in job applications?
10.1 If you submit a job application to Sinclair Peugeot, we will use the information provided by you to assess your application. Sinclair Peugeot may disclose the information contained in your application to contracted service providers for purposes such as screening, aptitude testing, medical testing and human resources management activities.
10.2 As part of the application process or (if you are successful in being employed by Sinclair Peugeot) after you commence employment with Sinclair Peugeot, you may be required to complete a health questionnaire. You may also be asked to undergo a medical assessment. In that case, you will be asked to give specific consent for Sinclair Peugeot to disclose your questionnaire to its service providers for the purposes of the medical assessment and for the relevant service providers to disclose the results of the assessment to Sinclair Peugeot.
10.3 If you refuse to provide any of the information requested by Sinclair Peugeot, or to consent to Sinclair Peugeot disclosing your questionnaire to its service providers for the purpose of a medical assessment or to the disclosure of the results of your medical assessment to Sinclair Peugeot, we may be unable to consider your application (or if you have been successful in being employed by Sinclair Peugeot, we may not be able to consider you for particular roles or positions within Sinclair Peugeot).
10.4 Sinclair Peugeot will handle health information in accordance with applicable laws and our Health Information Policy.
10.5 Sinclair Peugeot may also ask you whether you agree to your personal information being provided to appropriate Sinclair Peugeot suppliers so that you may be considered for positions with those suppliers which are relevant to your qualifications and experience.
11. Is the personal information we hold accurate?
11.1 We endeavour to maintain your personal information as accurately as reasonably possible. We rely on the accuracy of personal information as provided to us directly from you.
12. Links, cookies and use of the Sinclair Ford website
12.2 Sinclair Peugeot uses technology such as "cookies", "pixel tags" and java code on Sinclair Peugeot websites and in emails you have agreed to receive from us. The use of "cookies", "pixel tags" and java code is an industry standard, and helps us monitor the effectiveness of our advertising and how visitors use the Sinclair Peugeot Peugeot. A "cookie" is a small data element stored by your web browser on your computer system. Sinclair Peugeot website "cookies" do not store your email address or other personal information about you.
12.3 We use this technology to generate statistics and measure site activity to improve the usefulness of customer visits. During normal website usage we do not collect or store personal information such as your name, mailing address, email address or phone number.
12.4 Each time you access Sinclair Peugeot websites, the Sinclair Peugeot server may deliver certain customised information, including ads, to you based on the data stored in your cookie. Third party vendors may show our ads on sites on the Internet and serve these ads based on a user’s prior visits to our website and other Internet activity. Sinclair Peugeot may also use analytics data supplied by third party vendors to inform and optimise our ad campaigns.
13. How you can access and correct personal information we hold about you
14. Queries, comments and complaints about our handling of personal information
14.2 When contacting us please provide as much detail as possible in relation to your question, concern or complaint.
14.3 Sinclair Peugeot will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
14.4 If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner (click here for information).
15. Contact details
15.1Please address all privacy complaints to:
Attention: Privacy Officer
PO Box 341, Penrith NSW 2751
15.2 15.2 If you wish to seek access to or correct or update any personal information we hold about you, or to unsubscribe from or change your contact preferences in relation to our direct marketing, you can also contact us as follows: