Dealer Drive Privacy Policy

At Dealer Drive Australia Pty Ltd (ACN 165 751 093) (“Dealer Drive”, “we”, “our” or “us”) we recognise the importance of your privacy and understand your concerns regarding the security of the personal information which you provide to us.

This Privacy Policy details the type of personal information we collect when you use our websites, apps, software and services that link to this Privacy Policy (“Services”). This Privacy Policy also details how we store or process personal information about you, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to safeguard your personal information and tell you how to contact us regarding our privacy practices. We will only use the personal information collected from you in accordance with this Privacy Policy.

If you or your organization has an individual agreement with us, that agreement may have privacy terms that also apply to the information you provide to us under that agreement. Please review the terms in that agreement because they may be different or more restrictive than the terms in this Privacy Policy.

While our Services may contain links to websites owned by third parties, those websites are not subject to our privacy standards, policies and procedures. We recommend that you make your own enquires as to the privacy policies of these third parties and we are in no way responsible for the privacy practices of these parties.

By using our Services, you understand that we will collect and use your information as described in this Privacy Policy.

1. Definition of personal information

Personal information” or “personal data” means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.

2. How we collect and hold personal information

We collect certain personal information directly from you. For example, you provide us with personal information about yourself when you:

  • register or log-in to your account;
  • start, sign or review and electronic document;
  • create or edit your user profile;
  • contact customer support;
  • email us or call us;
  • comment on our blogs or in community forums; and
  • otherwise submit information to us via the Services.

We also collect other information about your online activities and your use of our Services automatically, usually from the use of Cookies and Pixel Tags. 

We may also collect information about you from other sources, such as from third parties.

If we receive personal information that we have not requested (unsolicited information) then we will destroy or de-identify the information if it is lawful and reasonable to do so.

3. What personal information we collect and hold

Information collected directly from you
We may obtain certain personal information from you when you choose to provide it to us.

Examples of the types of personal information that we may collect from you include:

  • contact information, such as your name, postal address, postcode, e-mail address and telephone number;
  • your drivers licence number and other details displayed on your drivers licence;
  • the type of car you test drove;
  • your car registration number;
  • your age and gender;
  • your username and password if you register an account; and
  • any other personal information you upload or submit to our Services.

Information we collect automatically
We may automatically collect information from you and your devices when you use our Services. This may include your IP address, the type of browser and device you use to access the Services, the web page you visited before coming to our websites, and other identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services that track your location and distance of your test drive.

We note that our websites are not designed to respond to “do not track” signals received from browsers.

Analytics 
We may use third-party web analytics services on our Services, such as Google Analytics. These service providers help us analyse how users use our Services. 

Information we collect from other sources
We may collect information about you from other sources, such ascar dealerships, third party service providers whose products integrate with our Services or other independent third parties who are legally allowed to share your information with us.

4. Cookies

We use technologies like cookies, pixel tags and web beacons to recognises you when you to visit our website or use our Services and to provide, improve, protect and promote our Services. 

What are cookies? 
A "cookie" is a small text file which is placed on your computer or device by our webpage servers when you access our Services. The purpose of a cookie is to help analyse web traffic and to allow our Services to respond to you when you return to our Services. Cookies are also used to enhance the secure use of our Services.

Cookies are frequently used and in themselves do not identify the user, just the computer used. 

How we use Cookies 
When you browse our website or use our Services, we may record geographical tagging, cookies and statistical data. This may include your IP address, date and time of your visit, operating system, language preferences, device characteristics, pages visited, information downloaded and type of browser used to access the Services.

Cookies help us: remember your username for your next visit; remember information regarding your recent drives; and understand how you are interacting with our Services so that we can improve them based on that information.

Web Beacons
We also may use “web beacons” on our Services. A web beacon, also known as a pixel tag or clear GIF, may be used to transmit information collected through cookies to our service providers’ servers, such as the server of Google AdWords. These web beacons enable our service providers to compile anonymous information about your browsing activity on the Services.

Disabling Cookies 
You can choose if and how a cookie will be accepted by configuring your preferences and options in your browser. However, if you decide not to display cookies you may not experience optimum performance of our Site.

5.  Why we collect, hold, use and disclose personal information 

We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities and as necessary to provide the Services to you. We also collect, hold, use and disclose your personal information for related purposes that you would reasonably expect, such as our administrative and accounting functions.

For example, we may use the information obtained through the Services at your request to:

  • create and manage your account;
  • market features, products, or special events using email or send you marketing communications about third party products and services we think may be of interest to you;
  • permit you to participate in blogs, forums, and discussion groups;
  • respond to and communicate with you about your requests, questions and comments; and
  • process claims we receive in connection with services.

If we do not collect, hold, use or disclose your personal information, or if you do not consent, then we may not be able to answer your enquiry, complete the transaction you have entered into, or provide our Services to you to the best of our ability.

In addition, we use information collected online through the use of cookies, pixel tags and other automated means. This information is used to: 

  • recognise your device when you use the Services;
  • track your test drives, including the distance and precise route of the drive;
  • manage our Services;
  • offer and provide products, services and information to you;
  • operate, evaluate and improve our business;
  • analyse your use of the Services;
  • personalise the Services, including targeted advertisements that may be of particular interest to you;
  • help diagnose technical and service problems;
  • identify users of our Services; and
  • gather demographic information about our users.

We use such information to help us to make decisions about maintaining and improving our Services and to assist us in providing an effective service (for example, to adapt our Services to the needs of your device or to allow you to log in to our Services).

We may also use your personal information for purposes which are required by law such as sharing your personal information in order to comply with legal obligations to which we are subject.

6. Ad Networks

You may see certain ads on other websites based on your visits to our Services because we participate in advertising networks administered by third-party vendors, such as Google AdWords. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs and web beacons. The networks use this information to show you advertisements that are tailored to your individual interests, to track your browser across multiple websites, and to build a profile of your web browsing. The information our ad network vendors collect includes information about your visits to websites that participate in the vendors’ advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Services and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

We may use the features of Google Analytics for Display Advertisers. That includes obtaining specific visitor cookie data, such as the source, medium and keywords used to visit our Services.

To learn more about how to opt out of ad network interest-based advertising, contact us using our contact details in section 17 of this Privacy Policy.

7. Marketing

We may use your information to offer you products and services that we think may be of interest to you, unless you have opted out of marketing communications.

Where required by applicable law, we will obtain your consent before sending you any marketing communications. You may withdraw your consent to the use of your data for marketing purposes at any time by contacting us on our contact details in section 17of this Privacy Policy.

We will never provide your information to third parties for marketing purposes without receiving your consent

8. Lawful Basis for Processing Your Information

If European Data Protection Laws applies, our lawful basis for collecting and using the information described in this Privacy Policy will depend on the information concerned and the specific context in which we collect or use it. 

We normally collect or use information from you where we have your consent to do so, where we need the information to perform a contract with you or to provide our services or products to you upon your request, or where the processing is in our legitimate interests and not overridden by your data protection interests or rights and freedoms.

For example, when we:

  • use information to create and manage your account, we need it in order to provide the relevant services;
  • record your test drive data, including location, we do so with your consent;
  • use information to effect a transaction you have requested, we need it in order to provide you with the product or services you are purchasing;
  • use names and email addresses for email marketing purposes, we do so with your consent (which you can revoke at any time); and
  • gather usage data and analyze it to improve our Services, we do so based on our legitimate interest in safeguarding and improving our Services.

If you have questions about or need further information concerning the lawful basis on which we collect and use your personal information, please contact us using the contact details in section 18 of this Privacy Policy. 

9. Disclosure of Information

Information shared to third parties
We will disclose personal information to third parties if it is necessary for the primary purpose of collecting the information, or for a related secondary purpose, if the disclosure could be reasonably expected. Where such a disclosure is necessary, we will require that the third party undertake to treat the personal information in accordance with all applicable privacy laws to which we are bound and in accordance with this Privacy Policy.

We may share your personal information as follows:

  • to companies that are related to us through common ownership; and
  • to contractors or third parties that support or assist us in providing our services to you; and
  • with third party integration partners whose products integrate with our Services.

Our service providers promise to safeguard your personal information and are not permitted to use it for their own purposes.

Where we wish to use or disclose your personal information for other purposes, we will obtain your prior consent.

Otherwise, we will only disclose your personal information to third parties without your consent if the disclosure is:

  • necessary to protect or enforce our legal rights or interests or to defend any claims;
  • necessary to prevent or lessen a serious threat to a person’s health or safety;
  • required or authorised by law; or
  • permitted by another exception in the applicable privacy laws.

Under no circumstances will we sell personal information without the consent of the person to whom it relates. Such consent, if given, may be withdraw at any time by contacting us using our contact details in section 17 of this Privacy Policy.

Information shared to your administrator 
Your administrator may have the ability to access and control your Dealer Drive account. They will be able to access the personal information that is submitted to our Services by you, including any your reviews and feedback you provide. They will also be able to access data in relation to your test drive, including the car you drove and the route of your test drive.

Please refer to your administrator's internal policies if you have questions about this. If you do not consent to your administrator having such access please inform your administrator and contact us using the contact details in section 17 of this Privacy Policy.

Third Party Analytics Services
We may use third-party web analytics services on our Services, such as Google Analytics. These service providers help us analyse how users use our Services. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. These service providers may retain and use anonymised, aggregated data collected from users of our Services in connection with their own businesses, including in order to improve their products and services.

To learn more about opting out of data collection through analytics services such as Google Analytics, please contact us using our contact details in section 17 of this Privacy Policy.

Company reorganisation
In the event that we undergo reorganisation or are sold to a third party, any personal information we hold about you may be transferred to that re-organised entity or third party in compliance with applicable law.

10. How we protect your personal information

We respect the privacy of personal information and will take reasonable steps to keep it strictly confidential. 

Your personal information may be held and stored on paper, by electronic means or both. We have physical, electronic and procedural safeguards in place for personal information and take reasonable steps to ensure that your personal information is protected from misuse, interference, loss and unauthorized access, modification and disclosure.

The steps we take to protect your personal information include the following: 

  • data held and stored on paper is stored in lockable offices and in secure premises;
  • data held and stored electronically is protected by internal and external firewalls, limited access via file passwords, and files designated read-only or no access;
  • when transferring information to others, we ensure that appropriate and suitable safeguards and data protection measures are in place to protect your personal information;
  • where we disclose personal information to third parties our contractual arrangements with them include specific privacy requirements;
  • only authorised personnel will have access to personal information;
  • our staff receive training on privacy procedures.

Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via our website whilst it is in transit over the internet and any such submission is at your own risk.

11. Overseas transfers of information

We aim to only hold and store your data in the country in which you reside or in which you accessed the Services. However your personal information may be transferred to our affiliates of service providers in Australia, the United Kingdom, Canada or elsewhere. By using our Services you consent to such disclosure. We will only disclose your information to such locations if permitted by law.

If your personal information is disclosed to another country we will ensure that any disclosure is in accordance with the relevant laws, and that appropriate safeguards are put in place.

If you would like further information regarding where your personal information is stored please contact us using our contact details in section 17 of this Privacy Policy. 

12. Retention of Information

We will only retain your personal information for as long as is reasonable necessary in relation to the purposes for which it was collected. We will also retain personal information to ensure compliance with any applicable statutory or regulatory obligations imposed on us in relation to the retention of records.

Where you have requested we stop processing your personal information for marketing purposes, we may retain a record of your request to ensure we abide by your request in the future.

13. Destruction and De-identification

When your information is no longer needed, or if you request that we delete any personal information which we hold about you, we will use secure methods to destroy or to permanently de-identify your personal information when it is no longer needed. For example, paper records are shredded or destroyed securely and any electronic records are deleted from all locations, to the best of our ability, or permanently de-identified.

14.Your Rights

Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights:

A. Request (i) information as to whether your personal information is retained and (ii) access to and/or duplicates of your personal information retained, including the purposes of the processing, the categories of personal information concerned, and the data recipients as well as potential retention periods.

B. Request rectification, erasure, removal or restriction of your personal information, for example, because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn.

C. Refuse to provide us with, or withdraw, your consent to processing of your personal information at any time.

D. Object, on grounds relating to your particular situation, that your personal information shall be subject to processing. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal information or present you our compelling legitimate grounds for an ongoing processing.

E. Object to us sending you direct marketing and profiling you for the purpose of direct marketing.

F. Object to your data being subject to any automated decision making, including profiling (decisions based on data processing by automatic means, for the purpose of assessing several personal aspects).

G. In certain circumstances receive your personal information that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from us. 

H. Lodge a complaint regarding our processing of your personal information with a relevant authority in a country where you live, work, or where you believe a breach may have occurred, or take legal action in relation to any potential breach of your rights regarding the processing of your personal information.

I. If you wish to contact us in relation to any of the rights outlined in this section, you can do so by contacting us using our contact details in section 18 of this Privacy Policy.

15. Children

Our Services are not directed at children under the age of 16.

If we learn that we have collected personal information of a child under 16 years old we will take steps to delete such information as soon as possible unless consent is given or authorised by the holder of parental responsibility over the child. If such consent is provided, the personal information will only be collected and used to the extent of the consent given.

16. Contact

If you have any questions, concerns, complaints or comments about this Privacy Policy or any requests concerning your personal information please contact us at [email protected].

17. Amendments to the Privacy Policy

We reserve the right to change this policy from time to time. Please check the Services regularly and check our respective current Privacy Policy.

This policy was last updated on 20 June 2018.