Version 1 April 2014 retrieve

1. Background

1.1 General

Sell My Car Pty Ltd ABN 55 166 924 456 (Sell My Car), trading as sellmycar.com.au, is committed to protecting your privacy in accordance with applicable Australian privacy laws.

This Policy describes the types of personal information we may collect about you, the purposes for which we use the information and the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy.

A copy of this Privacy Policy is available on the Sell My Car website at www.sellmycar.com.au/privacy-policy, or you can request a copy by contacting our Privacy Officer – details at 10.

1.2 What is personal information? Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

1.3 Employee records Sell My Car is generally exempt from the Privacy Act when it collects and handles employee records and this Privacy Policy does not apply to that information. Where State or Territory health privacy legislation applies, we are required to protect the privacy of employee health information. This Privacy Policy will apply in those circumstances.

2. What we collect

2.1 General

The type of personal information that we collect about you depends on the type of dealings you have with us. For example, if you:

• apply for an online valuation from us through our website using the valuation request form: the information we collect includes your name, telephone number/s, email address and post code
• request an onsite valuation from us: the information we collect includes your name, address, postcode, telephone number/s, email address and facsimile number (if applicable) and photo ID (driver s licence))
• contract with us to buy your car: the information we collect will include the information above and also personal identification (eg. date of birth, place of birth) that is included in documents to verify 100 points for personal identification purposes (eg. RTA/Government issued photo identification, birth certificate or passport). We may also obtain personal information about your role and responsibilities if you represent a business client. We may also collect your bank account details for payment to you
• arrange for a different person to be invoiced, we will also collect the same details in relation to the person to be invoiced
• send us an enquiry or provide us with feedback, we will collect your name, contact details, details of your enquiry or feedback and information about our response.
• apply for a job at Sell My Car, we will collect the information you include in your job application, including your cover letter, resume, contact details and referee reports.

2.2 Sensitive information

Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection, such as health information. Sell My Car only collects sensitive information where it is reasonably necessary for our functions or activities and either:

• the individual has consented; or
• we are required or authorised by or under law (including applicable privacy legislation) to do so. For example, we may collect your personal information as a director or principal of a company or business

2.3 Collection of information other than personal information through our website

When you visit the Sell My Car website, some of the information that is collected about your visit is not personal information, as it does not reveal your identity.

Site visit information

For example, our web host provider may record and provide to us your IP address, your top level domain name (for example, .com, .gov, .au, .nz etc), the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of browser and operating system you used.

This information is used and disclosed by Sell My Car in anonymous, aggregated form only, for purposes including statistical analysis and to assist Sell My Car to improve the functionality and usability of the website. You are not individually identified, however Sell My Car reserves its right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.

Cookies

Cookies are small text files that may be placed on your Web browser when you visit our website or when you view advertisements we have placed on other websites. Cookies allow your browser to remember some specific information which the Web server can later retrieve and use. We do not use cookies to store any personal information that could be read or understood by others. The cookies used by Sell My Car do not identify individual users, although they do identify the user s internet browser.

Cookies are used for administrative and statistical purposes to improve your experience with our website. Sell My Car s website makes use of both session and persistent browser cookies, so that we can provide you as a registered user with a member s page by authenticating you” when you sign in to our website and to make sure that they have agreed to our Terms and Conditions and Privacy Policy.

We may also use Cookies to conduct research and perform statistical analytics to improve the website and our products and services. This is done anonymously and we do not analyse individuals behaviour. Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. However this will mean that you are unable to take full advantage of the website s features.

Online Behavioural Advertising

Sell My Car uses advertising programs that place cookies on your computer to collect information about your browsing history (including on external websites). This information, which does not identify you personally, is collected in order to improve your online experience by customising the advertising you see to your interests (including the display of more relevant ads on external websites). You can opt out of these programs at any time by making direct contact with those providers. This information will not be combined with your Personal Information and is securely stored.

The information we may collect include your areas of interest that you indicate when visiting our website and we may use this for targeted marketing to you in relation to your interests. We may review overall consumer behaviour for individuals or groups, and use search engine marketing on other websites. Any advertisements that may appear are not on your computer but are on a browser banner.

Data Sharing Settings

Data is collected, processed and stored using third party analytical web utilities that are secure and confidential. Analytical data is used to gain an understanding of user behaviour, perform system critical operations, and in extraordinary circumstances for legal reasons.

Anonymous user data is shared between third party services in order to gain insight as to aggregate user behaviour. Analytic features implemented are based on Display Advertising (Remarketing, Display Network Impression and Demographics and Interest Reporting).

Using Ad Settings, visitors can opt out of Google Analytics for Display Advertising and customise the display network ads displayed. The opportunity to opt out of Google Analytics is available here.

We make use of remarketing to advertise online. Third party vendors, including but not limited to Google, may show our ads on sites across the internet. We and third party vendors, including but not limited to Google, make use of first-party cookies and third party cookies together in order to inform, optimise and serve ads based on past visits to a website.

We and third party vendors, including but not limited to Google, use first party cookies and third party cookies together to report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visitors to our website.

We make use of demographic data (such as age, gender and interests) obtained through third party tools in order to, but not limited to: influence marketing spend and communicate internally and externally aggregate behaviour.

We will not facilitate the merging of personally identifiable information with non personally identifiable information without prior user consent to that merger to optimise our website and website marketing; eg. we may collate personal information data and aggregate data for the purpose comparing marketing costs with revenue on a transactional basis.

Personally identifiable information is collected, processed and stored by Sell My Car where provided to us explicitly by registering manually or by sharing personal identifiable information by Facebook Connect or OpenID connection

Enable Demographics and Interest Reports

Demographics including but not limited to age and gender and interest data is made available to us by third party services (eg. Google and Facebook) so we can better understand our visitors.

2.4 Collection required or authorised by law

We may be required or authorised to collect personal information by or under an Australian law or a court/tribunal order including the following types of legislation applicable to the relevant State or Territory in relation to: Motor Vehicle Dealers, Consumer Law and Fair Trading, Unclaimed Money, Disposal of Uncollected Goods and Personal Property Securities.

3. How we collect personal information

3.1 Methods of collection

We collect personal information in a number of ways, including:

• in person for example, when you attend our premises to obtain an onsite valuation or to sell a car
• through the Sell My Car website (for example, if you submit an online valuation request)
• through the Sell My Car Facebook page, Twitter, SMS
• over the telephone
• from written correspondence (such as letters, faxes and emails)
• on hard copy forms (for example, competition entry forms and surveys) and
• from third parties
  • We may use various database providers for purposes such as, address validation software for personal information that we maintain which will verify your personal information against such sources as Australia Post however this software provider will not access your data.
  • We may use other database providers for customer assistance such as a system that enables us to link you to the nearest Sell My Car site when you make an enquiry online.

4. Why we collect personal information

The main purposes for which we collect, hold, use and disclose personal information are set out below:

• identify who is selling cars to us
• identify who is requesting and receiving valuations from us
• confirm whether any security interests are recorded in relation to car
• remitting funds to sellers and (where applicable) financiers
• promote Sell My Car and its products and services, including through direct marketing, events and competitions
• protect the security of our offices, staff, customers and the property held on our premises
• answer queries and resolving complaints
• recruit staff and contractors
• general account management, planning and administration

We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or which are:

• required or authorised by or under law (including, without limitation, privacy legislation) and
• for which you have provided your consent.

4.1 Direct marketing

Where we have your express or implied consent, or where we are otherwise permitted by law, we may:

• send you information about other products and services, including retail sales promotions, special offers and events.
• disclose your personal information to third party providers of finance, insurance, warranty and other related products and services that we think may be of interest to you (where we have entered into an agreement with the third party allowing them to market to you). You may be contacted with this information in a variety of ways, including by mail, email, SMS, facsimile, telephone or other electronic means.

Opting out

Where you have consented to receiving marketing communications from us, that consent will remain current until you advise us otherwise. However, you can opt out at any time by:

• contacting our Privacy Officer.
• advising us if you receive a marketing call that you no longer wish to receive these calls.
• using the unsubscribe facility that we include in our commercial electronic messages (such as emails and SMS) to opt out of receiving those messages.

To opt out of receiving marketing communications from third party providers, please make direct contact with those providers.

5. Who we may share your personal information with

We may share your personal information with third parties:

• if you sell an item to us, we may disclose your personal information to a person who buys the item from us- eg. service books may include your personal information
• information of sellers may be disclosed to third parties for purposes associated with the completion of the transaction (such as financial institutions for payment processing)
• the Personal Property Securities Register, to check whether any security interests are recorded in relation to an car sold to us
• state and federal government authorities (for example for car registration and compulsory third party insurance purposes, the Office of State Revenue for unclaimed money, ASIC in checking directors details for companies)
• referees whose details are provided to us by job applicants
• Sell My Car s contracted service providers, including:
  • delivery and transport providers
  • insurers
  • information technology and data storage providers
  • function and event organisers
  • marketing and communications agencies
  • research and statistical analysis providers
  • call centres
  • mail houses
  • external business advisers (such as recruitment advisors, auditors and lawyers).

In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services.

Non affiliated companies that assist Sell My Car in providing services to you are required to maintain the confidentiality of such information to the extent that they receive it and to use your personal information only in the course of providing such services and only for the purposes that Sell My Car dictates.

6. Cross border disclosure of personal information

Sell My Car does not currently and is not likely to disclose personal information to third parties located overseas. If this changes in the future Sell My Car will comply with the requirements of the Privacy Act that apply to cross border disclosures of personal information and this Privacy Policy will be amended accordingly.

7. Data quality and security

7.1 General

Sell My Car limits access to your information to authorised Sell My Car employees or agents and our service providers are held to stringent standards of privacy. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorised access or disclosure. Some of our features of our information security program include:

• A dedicated information security group within the IT department that designs, implements and provides oversight to our information security program
• Use of specialised technology such as firewalls and CloudFlare for denial of service
• Testing of the security and operability of products and services before they are introduced to the internet, as well as ongoing scanning for publicly known vulnerabilities in the technology
• Internal and external reviews of our internet sites and services
• Monitoring our systems infrastructure to detect weaknesses and potential intrusions
• Implementing controls to identify, authenticate and authorise access to various systems or sites
• Protecting information during transmission through various means
• Specific requirement for database backup and retention
• Providing Sell My Car personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

We hold personal information in a number of ways, including in hard copy documents, electronic databases, email contact lists, and in paper files held in a secure manner. Paper files may also be archived in boxes and stored offsite in secure facilities. We take reasonable steps to:

•  ensure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant
• protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure
• destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the APPs. You can help us keep your information up to date, by letting us know about any changes to your details, such as your address, email address or phone number.

 7.2 Security

The steps we take to secure the personal information we hold include website protection measures (such as firewalls and anti-virus software), security restrictions on access to Sell My Car s computer systems (such as login and password protection), controlled access to Sell My Car s corporate premises, policies on document storage and security, personnel security (including restricting access to personal information on Sell My Car s systems to staff who need that access to carry out their duties, staff training and workplace policies).

Online credit card payment security

Sell My Car processes payments using EFTPOS and online technologies. All transactions processed by Sell My Car meet industry security standards to ensure payment details are protected.

Website security

While Sell My Car strives to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact Sell My Car by telephone or post (details under 10 below).

If you are registering details on the Sell My Car website, you can also help to protect the privacy of your personal information by ensuring that you log out of the website when you have finished using it. In addition, if you become aware of any security breach, please let us know as soon as possible.

8. Access and Correction

If you would like to access or correct the personal information that we hold about you please contact our Privacy Officer. We may ask you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.

9. How we will deal with your Complaints

If you have a complaint about how Sell My Car has collected or used your personal information, please contact the Privacy Officer and, if required, complete a Privacy Complaint Form (here), that asks you to explain the circumstances of your complaint, how you believe your privacy has been interfered with and how you believe your complaint should be resolved.

We will endeavour to acknowledge the Privacy Complaint form within 7 business days from receipt. In most cases a response to a complaint will be provided in 30 days of receipt of a Privacy Complaint Form. We will advise you of any delay in the response.

We will throughout the dispute resolution process, ensure that we provide you with the opportunity to communicate with us and negotiate and we will attempt to resolve your complaint in a fair and reasonable manner.

10. Our contact details

Please contact our Privacy Officer using the contact details below if you have any queries about Sell My Car and privacy:

Mail: Sell My Car Privacy Officer, PO Box 34, Altona North, Victoria, 3025, Australia

Email: talktous@sellmycar.com.au

Telephone: 1300 474 777

11. Changes to this Policy

This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our website.

This version of the Policy is effective 1 April 2014.