Web Site Privacy Policy of Grand Motors Toyota

Privacy Policy

1. Introduction

1.1 Grand Motors Pty Ltd is part of the OneToyota network of Toyota organisations in Australia (each a OneToyota organisation), comprising: 

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

1.2 We operate a vehicle dealership in Australia that provides a range of automobile related services including sales of new and used vehicles, servicing, parts, vehicle finance and merchandise. 

1.3 In the course of our business, there are circumstances where we collect personal information. This privacy policy has been developed to ensure that this information is handled appropriately.

1.4 We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. Our commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles which set out the way in which personal information must be treated. 

1.5 This privacy policy also incorporates our policy on managing credit information (see particularly section 7.1 onwards).

Who does the privacy policy apply to? 

1.6 This policy applies to any person for whom we currently hold, or may in the future collect, personal information. 

1.7 Generally, we only collect personal information from customers and from prospective employees.

What information does the privacy policy apply to?

1.8 This policy applies to personal information. In broad terms, 'personal information' is information or opinions relating to a particular individual who can be identified.

1.9 Information is not personal information where the information cannot be linked to an identifiable individual.

2. How do we manage the personal information we collect?

2.1 We manage the personal information we collect in numerous ways, such as by:

1. implementing procedures for identifying and managing privacy risks;
2. implementing security systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure;
3. providing staff with training on privacy issues; 
4. implementing procedures for identifying and reporting privacy breaches and for receiving and responding to complaints;
5. appointing a privacy officer within our business to monitor privacy compliance; 
6. having access to audit trails of information accessed; and
7. allowing individuals the option of not identifying themselves, or using a pseudonym, when dealing with us in particular circumstances. 

2.2 We will take reasonable steps to destroy or permanently de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.

2.3 In limited circumstances, it may be possible for you to use a pseudonym or remain anonymous when dealing with us (for example, when making a general enquiry with us). However, if you would like to purchase a vehicle or parts or engage us for services, we will need your personal information in most instances in order to supply you with the vehicle, parts or service.

3. WHAT KINDS OF INFORMATION do we COLLECT AND HOLD?

Personal information

3.1 We may collect and hold personal information about you, which may include:

1. sensitive information (see below); 
2. contact information; 
3. financial information;
4. date and place of birth;
5. gender;
6. employment arrangements and history;
7. tax file numbers; 
8. trade qualifications (for potential employees);
9. insurance information;
10. credit information; 
11. banking details; and
12. any other personal information required to provide the vehicle, parts or service for you.

Sensitive information 

3.2 ‘Sensitive information’ is a subset of personal information and includes personal information that may have serious ramifications for the individual concerned if used inappropriately. 

3.3 The sensitive information we might collect and hold about you may include any of the following:

1. criminal records; 
2. membership of professional or trade associations; and
3. membership of trade unions.

3.4 We will not collect sensitive information without the consent of the person to whom the information relates unless permitted under the Privacy Act.

4. How and when do we collect personal information? 

4.1 Our usual approach to collecting personal information is to collect it directly from you.

4.2 We may also collect personal information in other ways, which may include:

1. through marketing and business development events;
2. through our website; 
3. from our related entities;
4. from businesses in which you are employed;
5. from insurance or financial providers and brokers;
6. from government bodies (such as state transport departments and the Australian Taxation Office); 
7. through referrals from individuals or other entities;
8. from third party providers and suppliers (such as vehicle manufacturers or distributors); 
9. from colleagues, associates or relatives of yours; and
10. through competitions.

5. How do we hold personal information?

5.1 We generally hold personal information:

1. physically:
   1. at our premises (securely); and
   2. off-site, by third party physical storage providers (securely); and
2. electronically:
   1. on secure online servers; and
   2. on our website.

5.2 We secure the personal information we hold in numerous ways, including:

1. using access codes to access areas that contain personal information;
2. using secure servers to store personal information;
3. using unique usernames, passwords and other protections on systems that can access personal information; and
4. regularly destroying documents that are no longer needed subject to legal obligations for record keeping. 

6. Why do we collect, hold, use or disclose personal information?

6.1 We take reasonable steps to use and disclose personal information for the primary purpose for which we collect it. The primary purpose for which information is collected is generally to provide you with new or used vehicles, parts for vehicles or to service your vehicle.

A full range of the services we offer can be found at http://www.grandmotorstoyota.com.au.

6.2 In the case of potential employees, the primary purpose the information is collected is to assess the individual’s suitability for employment.

6.3 Grand Motors Toyota and other One Toyota organisations collect and share with each other customer and guest information, including data collected from Connected Services, to provide you an integrated One Toyota guest experience, such as allowing you to be known across the network regardless of which One Toyota 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 One Toyota 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.

6.4 Personal information may also be used or disclosed by us for secondary purposes which are within your reasonable expectations and which are related to the primary purpose of collection. For example, we may collect and use your personal information:

1. to keep record of transactions to assist in future enquiries and enhance our customer relationship with you;
2. for delivery purposes;
3. to send you special offers and promotional material; and
4. to invite you to events.

6.5 For example, 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.

6.6 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.

6.7 We may disclose personal information to:

1. our suppliers;
2. our related entities; 
3. government bodies (such as state transport departments or the Australian Taxation Office);
4. business support service providers (for example our software suppliers, law and accounting firms, manufacturers, insurance providers, or other consultants); and
5. any other third party we deem necessary in connection with providing you with the vehicle, parts or services (such as vehicle manufacturers or distributors).

6.8 Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act.

7. Will we disclose personal information outside Australia?

7.1 Generally, we do not disclose personal information outside of Australia but, from time to time, it may be necessary to disclose personal information to vehicle manufacturers, their contractors or agents located in Japan, Singapore, United States of America, United Kingdom and Sweden. 

7.2 Your personal information will not be disclosed to any overseas recipients unless we are satisfied that the receiving party provides commitments to privacy and confidentiality which are at least equal to the Australian Privacy Principles or the recipient is subject to privacy protection laws that offer at lease the same level of protection as required under the Privacy Act in Australia.

8. How do we manage your credit information?

What kinds of credit information may we collect?

8.1 In the course of providing new or used vehicles, parts for vehicles or services, we may collect and hold the following kinds of credit information:

1. your identification information;
2. information about any credit that has been provided to you; 
3. your repayment history;
4. information about your overdue payments;
5. if terms and conditions of your credit arrangements are varied;
6. if any court proceedings have been initiated against you in relation to your credit activities;
7. information about any bankruptcy or debt agreements involving you;
8. any publicly available information about your credit worthiness; and
9. any information about you where you may have fraudulently or otherwise committed a serious credit infringement.

8.2 In some circumstances, we may collect credit information and personal information from credit reporting bodies (e.g. Dun & Bradstreet). The kinds of information we collect may include any of those kinds of information outlined in sections 3.1, 3.3 and 8.1 of this policy.

8.3 We may also collect personal information which may affect your credit worthiness from other credit providers, who have collected that information from a credit reporting body. The kinds of personal information we collect may include any of those kinds of personal information outlined in section 3.1 of this policy.

How and when do we collect credit information?

8.4 In most cases, we will only collect credit information about you if you disclose it to us. 

8.5 Other sources we may collect credit information from include:

1. credit reporting bodies (e.g. Dun & Bradstreet);
2. other individuals and entities via referrals; and
3. suppliers and other creditors.

How do we store and hold the credit information?

8.6 We store and hold credit information in the same manner as outlined in section 5 of this policy.

Why do we collect the credit information?

8.7 Our usual purpose for collecting, holding, using and disclosing credit information about you is to enable us to provide you with the requested vehicle, parts or service. 

8.8 We may also collect the credit information:

1. to process payments;
2. to assess eligibility for credit; and
3. for any other purpose that we consider necessary to best provide you with the requested vehicle, parts or  services.

Overseas disclosure of the credit information

8.9 We will not disclose your credit information to entities without an Australian link unless you expressly request or authorise us to.

How can I access my credit information, correct errors or make a complaint?

8.10 You can access and correct your credit information, or complain if you believe there has been a breach of your privacy in the same manner as set out in section 9 of this policy.

9. How do you make complaints and access and correct your personal information or credit information?

9.1 It is important that the information we hold about you is up-to-date. You should contact us if your personal information changes.

Access to information and correcting personal information

1.1 You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.

1.2 Subject to section 9.4, we will grant you access to your personal information as soon as possible.

1.3 In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.

1.4 We may deny access to personal information if:

1. the request is unreasonable;
2. providing access would have an unreasonable impact on the privacy of another person;
3. providing access would pose a serious and imminent threat to the life or health of any person; or
4. there are other legal grounds to deny the request.

1.5 We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.

1.6 If the personal information we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, where it is appropriate to do so. 

1.7 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 http://www.toyota.com.au/privacy-policy. The privacy policies of Toyota Insurance and Toyota Western Australia are each also available at that address.

Complaints

1.8 If you wish to complain about an alleged privacy breach, you must follow the following process:

1. The complaint must be firstly made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint.
2. In the unlikely event the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.

Who to contact

1.9 A person may make a complaint or request to access or correct personal information about them held by us. Such a request must be made in writing to the following address:

Privacy Officer:            Financial Controller
Postal Address:           PO Box 7834
                                            GCMC  QLD  9726
Telephone number:    07 5583 6888
Email address:             privacy@grandmotors.com.au

2. Changes to the policy

2.1 We may update, modify or remove this policy at any time without prior notice. Any changes to the privacy policy will be published on our website.

2.2 This policy is effective November 2020. If you have any comments on the policy, please contact the privacy officer with the contact details in section 9 of this policy.