PRIVACY POLICY

INTRODUCTION

This Policy contains important information about how we manage personal information. It applies to all of the services offered by HYVE CORPORATION LIMITED ABN 90 674 037 631(HCL, we,us,our) all our related companies, and the platforms through which we interact with you, including the Carbee website, your Carbee Customer Account, HCL’s social media accounts (social  media) and any Carbee call centre). We may modify this Policy at any time, and if we do, we will publish it on our website.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles contained within that Act. The Services we provide include details of pre-owned motor vehicles publicly available for sale in Australia  from our subscribers, and other information about finance, insurance, accessories, and other add on products and services relevant or possibly relevant to those motor vehicles. The services we offer may change from time to time.

 

PERSONAL INFORMATION WE COLLECT

Depending on your interaction with us, the information that we collect about you may include (but is not necessarily limited to) your name, telephone numbers, email and home and/or work address, date of birth, gender, insurance history, employment information, marital status, number of dependants, proof of identification information (e.g. driver’s licence,) details regarding your financial circumstances (e.g. existing home loans and savings) and future requirements, details about any real property you own or rent, and your contact details. In some cases we may collect information that is generic, and which is not  identifiable (such as location data, your age, data about personal attributes etc) but which, taken together with other collected data, may identify you, either directly or indirectly. Where practicable, we will allow you to deal with us anonymously or by using a pseudonym.

Sensitive Information

We will not collect any sensitive information from you. Sensitive information includes any information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or health information.

 

HOW WE COLLECT AND HOLD PERSONAL INFORMATION

We collect personal information from you:

• Directly and voluntarily;

• Automatically

• Via third party sources..

 

 Information provided voluntarily by you

We collect personal information that you provide to us, including when you:

• Create or use a customer account on our website or through our mobile application;
• Interact with our website or call centre;
• Interact with our social media, including communicating with us via social media platforms;
• Subscribe to electronic communications;
• Enter promotions or competitions, depending on the entry requirements;
• Submit an enquiry or complaint, provide feedback or make a customer service request;
• Download our software and/or mobile applications, where you may provide your name, contact details and other information for the purposes of accessing and using the service;
• Participate in surveys, market research or audience testing.

Personal information that you provide to purchase products or services on third party websites which are linked to our website is collected and managed by those third parties (see our Website Terms and Conditions, available on the websites, for more information about those third party websites).

 

Information collected automatically

We generate and maintain a record of information when you visit our website. HCL uses cookies or similar types of technology to automatically collect information including your IP address, the device you use to access our website or social media, your location, the sites you visit immediately before or after our website and the frequency and duration of your interactions with our website. We may track activity relating to your interaction with our email communications and with links embedded in email communications and our website or social media. This type of information is usually collected, used and stored by HCL to measure the effectiveness of our advertising and how visitors use our website in order to:

• provide you with a better and more customised service and a more effective website and to manage our relationship with you;
• collect information on how many visitors the website receives, how those visitors use the website, where they came from and where they go after accessing the website; and
• determine whether you have made purchases of certain products elsewhere, after using our website.

 You can configure your browser so it does not accept cookies, but this may affect the functionality of our website. We may also collect and store information on your personal device using browser web storage and data cache Information provided by or collected from third parties We may also  be provided with or collect information from third parties about you. This can include where:

• we engage organisations to collect personal information directly and voluntarily from you on our behalf. Where reasonably possible, we require organisations engaged on our behalf to comply with this Policy and all applicable privacy laws and regulations.
• we receive information from our participating suppliers, for example, after you purchase a product from the supplier after interacting with HCL;
• we engage an organisation to conduct market research or audience testing; or

Information from third party sources

We may use analytics tools, web beacons and other technology to obtain aggregated and nonidentifiable information such as usage and user metrics collected by third parties when you interact with our website and social media. Organisations who collect such information may aggregate information collected from your interactions with us with other information they have also collected elsewhere. Third party organisations typically collect and use information under their own privacy policies.

If we collect information about you from a third party, we will determine whether we could have lawfully collected that information directly from you and, if not, we will destroy or de-identify that information (provided it’s lawful to do so).

 

WHY WE COLLECT, HOLD AND USE PERSONAL INFORMATION

We generally collect, hold, and use personal information about you for four purposes:

1. service provision;
2. communication;
3. optimization and enhancement of our platform; and
4. marketing and advertising.

We may notify you that we also collect, hold and use personal information for other purposes from time to time. Where required or permitted by law, we may also share your personal information with third parties.

 

Provision of services and products to you

We use your personal information:

• to provide you with our services and products including via our website or via our call centre;
• to provide to our business partners, advertisers, or subscribers so that they can (where you have agreed) contact you to arrange for an inspection, test drive or delivery of a motor vehicle;
• to provide to any mortgage broker/s we refer you to, to assist you with any enquiry you make about possible financial options when purchasing a motor vehicle;
• to provide to our service providers so that they can provide us with services that assist us to run our business and our websites and social media;
• to reconcile transactions with our business partners or subscribers that supply you products because of our services;
• to communicate with you about our loyalty program;

Communication

We use your personal information to provide you with customer support, including dealing with complaints and enquiries. We may also use your information for other activities including:

• to send you a summary of your search results;
• to administer competitions and promotions;
• to send special offers or reminders;
• to seek your opinions and feedback; and
• to telephone you about the services and products we offer.

If you win a competition that we (or our agents) run, we may also seek your consent to use your name, image (e.g. photograph) and/or voice recordings for the purpose of promoting or marketing the competition and/or our services.

 

Optimisation and enhancement

We use your personal information to provide, improve and maintain our website and call centres and the Services we offer, including to develop new products and services. Your information may also be used:

• to prevent abuse and fraud;
• in conjunction with other information, for analytical and statistical purposes;
• to personalize and customise your online experience, including advertisements and content; and
• for other administrative and internal business purposes.

We may record details or block particular I.P. addresses (and where required provide those details to third parties) to assist us to maintain the integrity of our website where there is suspicious or excessive use of the website. If you have a customer account, we may use the information from that account to prefill relevant fields on our website to assist you to complete an inquiry about any vehicle (or other activity) or otherwise to personalise or streamline our service delivery to you.

 

Marketing & Advertising

We use your personal information to market and advertise our business and products and services to you. Your information may also be used to customize and display advertisements and content for you. We may use various services or organisations to analyse collected data about your interaction with our website, services or other aspects of our business. The information that is collected is not generally personally identifiable as it is aggregated data that does not identify any individual user.

 We will not link or merge information collected by us with information collected by third party organisations without your consent. However, Google, Facebook or other third parties may merge or link your information if you have provided your consent for them to do that.

 

KEEPING YOUR PERSONAL INFORMATION SECURE

We store personal information on networks in Australia and in the cloud.  . We will take all reasonable precautions to ensure that the personal information that we have about you is protected against any unlawful use, unauthorised access, modification or disclosure and these precautions include:

• using appropriate information technology and processes;
• using computer and network security systems with appropriate firewalls, encryption technology and passwords for the protection of electronic files;
• securely destroying or “de-identifying” personal information if we no longer require it subject to our legal obligations to keep some information for certain prescribed periods; and
• restricting access to your personal information to our employees and those who perform services for us who need your personal information to do what we have engaged them to do;
• requesting certain personal information from you when you wish to discuss any issues relating to the products and services we provide to you.

While we undertake reasonable steps to protect your personal information, no guarantee can be given that information sent over the internet is always 100% secure. Sending and receiving information over the internet is at the user’s own risk, however we will take all reasonable steps to ensure your data remains secure once we receive it.

If we believe or suspect that the security of your Personal Information has been compromised, we may attempt notify you electronically so that you can take steps to protect yourself from harm.

 Where reasonably possible, we will destroy or de-identify your information if it is no longer required for the purpose for which it was collected or any related purpose (subject to any relevant record keeping obligations under Australian law).

 

Transfer of information outside Australia  

Please note that some of our suppliers and business partners may operate their businesses from premises or call centres that are based overseas.  So if you enquire about a product with them, you may be dealing with someone located outside Australia . If you provide information to one of these businesses or call centres, the collection, storage and use of that information will be managed by the participating supplier and is subject to their privacy policy and to the laws of the jurisdiction in which they are located

 

WHEN WE DISCLOSE PERSONAL INFORMATION

We do not sell, license or otherwise disclose your Personal Information to third parties unless such disclosure is for the purposes set out in this Privacy Policy.

Participating suppliers

We may provide your information to participating suppliers to enable suppliers to provide products and services to you. This may include providing your information to a supplier:

• if you wish to obtain a quote for a vehicle, or other products or services; and
• if you decide to enter into an agreement with that supplier or wish to obtain further information.

 

Third party affiliates and service providers

We may provide your information to our third-party affiliates who carry out services on our behalf or to service provider to enable service providers to perform business functions for us. Whenever possible, we require such third parties to only collect and use Personal Information in accordance with this Policy, and for no purpose other than providing us with our requested services.

Co-branding

If you use a product or service that is co-branded or that is part of a joint promotion involving us and one or more third parties, your information may be collected by each party. Generally, we do not control the management or use of information by third parties. You should consult each respective privacy policy to confirm how each party will management and use your information.

 

Legal requirements

We may disclose your information if, in our reasonable opinion, we are legally bound to do so or if such disclosure is necessary to prevent harm to ourselves, other users or third parties. We will notify you of such disclosures unless we are legally unable to do so.

 

Change of ownership

If there is a change of control of our company, your information may become accessible by a third party if we are required to transfer assets to them.

 

Interactive platforms

Any personal information that you submit, display or publish on an online platform or website, including social media, is publicly available and may be read, collected, used and disclosed by us or other users of those platforms subject to the terms of use of those sites. If you decide to interact with us via social media, your limited data from your social media profile may be collected and provided to us or other third parties.

 

ACCESS TO YOUR PERSONAL INFORMATION

You have the right to access and correct your personal information we hold. In certain situations (e.g. if required or permitted by law), we can deny access to some or all the personal information we hold. We will always provide reasons in writing if access is refused. We may charge you a reasonable fee for access to your personal information, but we will advise you of the fee before we process your request. We will always respond to requests for access and/or corrections within a reasonable period and we will give access in the manner requested if it is reasonable and practicable to do so.

Please email or write to our Privacy Officer (see Contact Information) if you wish to access or correct your personal information. If you provide us with information about another person, you must have that person’s consent before you provide the information to us. You must also tell the person we have collected their personal information; the person is entitled to access the information we hold; and he or she should refer to this document to understand how we manage their personal information.

 

DATA DELETION OR UNSUBSCRIBE FROM MARKETING COMMUNICATIONS

If you no longer wish to receive marketing communications from us, please use the unsubscribe link contained in all of our email communications. If you use the unsubscribe link in our email communications, you will be removed from the distribution list for email communications, but you may continue to receive communications from us by SMS or phone. You can contact us by calling 1800### ### or email [email protected] to opt out of all communications or request the deletion or your personal information or customer account.

 

PRIVACY COMPLAINTS

If you have a complaint about the way we manage your personal information, including any decision made regarding a request for access or correction of your personal information, then you are able to do so in a number of ways:

• we suggest that you first contact the staff member you have been dealing with and they will do their best to resolve your issue. If investigation is required, we will keep you advised of the progress.
• If staff are unable to resolve the matter, it will be referred to our Public Access Unit;
• you can phone our Public Access Unit on toll free number 1800 ### ### any time between 8.30am and 5pm Monday to Friday; or
• you can email your issue to [email protected].
• You can write to us at Privacy Manager, Carbee Ltd, PO Box #### Melbourne.

 

If a privacy issue is not resolved to your satisfaction or you wish to obtain more information on the privacy legislation, you can contact the Office of the Australian Information Commissioner (phone 1300 363 992 Monday to Friday during business hours, email: [email protected]. Or write c/- GPO Box 5218 Sydney NSW 2001)

 

For anything else about our Privacy Policy, please contact our Privacy Officer (see Contact Information): Our Privacy Officer will endeavour to resolve any privacy complaints and will respond in writing to you regarding the outcome of any investigation

CONTACT INFORMATION

Privacy Compliance Manager: Peter Carroll 

Email                [email protected]

Website            carbee.com.au