Noble Volkswagen APP Privacy Policy
The statement below encompasses our Privacy policy. Some of the terms are quite technical but please bear with us as we explain we manage your personal information and other information. Effective 12 March 2014 there were a number of changes made to the Privacy Act 1988 introduced to parliament and passed with amendments as the Privacy Amendment (enhancing Privacy Protection) Act 2012. Australian Privacy principles were introduced to replace the existing National Privacy Principles. Details of the changes can be obtained from the Office of the Australian Information Commissioner (www.oaic.gov.au)
Noble Volkswagen values your privacy and the security of your personal information.
Oltoy Pty Ltd (ACN 075 865 548) (Noble Volkswagen) aims to provide its customers with the best possible products and services. We also want our customers to have confidence that we afford personal information an appropriate level of privacy.
Please note that Volkswagen Group Australia Pty Ltd (Volkswagen Australia) operates separately to Noble Volkswagen. For details of Volkswagen Australia's Privacy Policy at https://www.volkswagen.com.au/en/privacy-policy.html
What is Personal Information?
Personal information is information in any recorded form that identifies an individual or from which an individual's identity can reasonably be ascertained. Examples include an individual's name, address, contact number and email address.
Why does Noble Volkswagen collect personal Information?
Noble Volkswagen collects personal information for a range of purposes, including to:
- Respond to customer queries about the products and services that we offer
- Confirm that customers are properly licensed for the purposes of taking a test drive
- Supply products and services (including new and used vehicles, parts, accessories and any applicable warranties)
- Process payment for products and services (including considering applications for credit where relevant)
- To coordinate delivery of your vehicle and ensure that your vehicle is delivered to your satisfaction
- Consider, process and record the purchase of trade-in vehicles
- Carry out vehicle repairs and servicing, supply parts and accessories, supply products such as lubricants and automotive fluids and maintain any applicable warranties
- Arrange for products and services to be supplied to customers by third parties (including Noble Volkswagen sub-contractors) where appropriate (for example, extended warranty and roadside assistance services and financial and insurance products in respect of vehicles purchased from us; or fitment of non-genuine parts and accessories, panel beating services or windscreen replacement in respect of vehicles we are repairing) (these people may contact you directly for this purpose);
- To conduct competitions
Noble Volkswagen also uses the personal information that it collects to:
- Maintain records for accounting and administration purposes
- Administer warranty claims
- Provide customer support
- Respond to customer complaints
- Administer safety-related product recalls
- Analyse customer needs and develop customer strategies
- Meet legal and regulatory requirements
If you choose not to provide certain information about you, we may not be able to provide you with the products or services you require, or the level of service on which we pride ourselves.
Customer satisfaction surveys, service reminders and direct marketing
From time to time, Noble Volkswagen surveys its customers on a range of issues, including new vehicle satisfaction and the quality of our service. These surveys help us to improve our products and services and tailor the way that we do business with you. If you do not wish to participate in these surveys, please contact Noble Volkswagen.
If you consent, Noble Volkswagen may use your personal information to send you service reminders and information about our products and services, including special offers. We may also send our customers information about products and services of businesses associated with Noble Volkswagen. If you no longer wish to receive this information, please contact Noble Volkswagen.
If you choose not to provide certain information about you, we may not be able to provide you with the products or services you require, or the level of service on which we pride ourselves.
The type of personal information that we collect will depend on the circumstances of collection. For example, we may collect your name, date of birth, address, telephone number, email address and vehicle purchase and service history. For vehicle purchases, we also collect information such as the vehicle make, model and colour, options and accessories supplied, price paid, trade-in details, vehicle identification number, registration details, driver's licence number, odometer reading, finance and insurance details and details of any roadside assistance services or extended warranty purchased. We may also collect details of other interactions that you have with us, together with any other information that you choose to provide us with.
The collection of sensitive information is restricted by the Privacy Act. Noble Volkswagen will not collect sensitive information about an individual unless this is necessary for one of Noble Volkswagen's functions or activities and the individual has consented to that collection, or Noble Volkswagen is otherwise required or authorised by or under law to do so.
How does Noble Volkswagen collect personal information?
Much of the personal information that we hold is collected when you purchase a vehicle or parts and accessories from us, when you trade-in a vehicle or when you have your vehicle repaired or serviced by us. We may also collect personal information in a number of other ways, for example when you:
- Contact us with a query (whether in person, or by phone, fax, email, through the forms on the Noble Volkswagen website)
- Take a vehicle for a test drive or require the use of one of our loan vehicles
- Enter a competition conducted by us
- Respond to one of our direct marketing campaigns
We may also collect information from you online in response to your enquiry.
If you have purchased a vehicle with the Volkswagen Link system, information such as vehicle diagnostic data, odometer reading, vehicle location and vehicle speed will be collected directly from your vehicle. Please refer to the Volkswagen Link Subscription Agreement for further details.
Website Collection of Information
Some of the information that is collected on our website is not personal information, because it does not reveal your identity. For example, we may record your server address, domain name, the date and time of your visit to this site and the pages that you viewed. This information is used by us in anonymous, aggregated form only, for statistical and web site development purposes.
However, Noble Volkswagen reserves its right to use or disclose this information to try to locate an individual if it reasonably believes that the individual may have engaged in any unlawful or inappropriate activity in connection with this website.
A cookie is a small data file that a web site transfers to your internet browser for identification purposes. The cookies that we use do not identify you individually. Instead, they identify your internet browser.
We use cookies to maintain session information about you when you log into our website, which enables us to personalise your current visit.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can however limit the functionality of this website.
Third Party Collection of Information
Sometimes, we may collect your personal information from third parties, for example where:
- You respond to a Customer Satisfaction Survey conducted by Volkswagen Australia or a vehicle industry survey and the survey results are provided to Noble Volkswagen
- We collect information such as your warranty details and service history from Volkswagen Australia or from another authorised Volkswagen dealer, to facilitate the provision of services to you
- We have arranged for third parties to supply you with products and services and those third parties provide us with information about the products or services that you have purchased from them (please note that we do not collect your credit or financial details from finance or insurance suppliers)
What if you don't provide your personal information to Noble Volkswagen?
If Noble Volkswagen is unable to collect personal information from or about you, it may prove difficult to do business with you or your organization. Noble Volkswagen may not be able to provide you with the products or services you require, or the level of service on which we pride ourselves.
When does Noble Volkswagen disclose personal information to third parties?
In providing our customers with products or services, we may disclose personal information to third parties. In particular, your personal information may be disclosed to Volkswagen Australia and their related bodies corporate. Information such as warranty details and service history may also be disclosed to other authorised Volkswagen dealers, to help them better serve your needs.
Other third parties with whom we may share your personal information include, where appropriate:
- Finance, insurance, extended warranty and roadside assistance providers (where you have requested that they supply products and services to you)
- Providers (including Noble Volkswagen sub-contractors) of outsourced vehicle repair and maintenance services (such as panel beaters and windscreen repairers) (these people may contact you directly for this purpose)
- Valuers (to assess the value of your vehicle) and vehicle registries (to check whether a trade in vehicle is encumbered)
- Government authorities (for example for vehicle registration and compulsory third party (bodily injury) insurance or as required under financial transactions reporting or anti-money laundering legislation) police, local council authorities or our insurers if a test drive or hire vehicle is involved in any parking or traffic infringements or is damaged whilst in your possession
- Financial institutions for payment processing referees, referrals or guarantors whose details you have provided to us
Noble Volkswagen's contracted service providers, include:
- Website designers and information technology service providers
- Marketing and communications agencies
- Call centres and call training centres
- Mailing houses, freight and courier services
- Printers and distributors of direct marketing material
- External business advisors (such as auditors, lawyers and debt collectors)
In the case of contracted service providers, we may disclose personal information to the contracted service provider and the contracted service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services. We take steps to help ensure that our contracted service providers comply with the APPs when they collect and handle your personal information.
We may also disclose personal information to third parties where required or authorised by or under law to do so with your consent (which may be written, verbal or implied from your conduct).
Keeping your personal information up to date
We will take such steps (if any) as are reasonable in the circumstances to ensure that the personal information that Noble Volkswagen collects is accurate, up to date and complete.
Security of personal information
The security of information is important to Noble Volkswagen and we take precautions to protect the personal information that we hold from misuse, loss, unauthorised access, modification or disclosure.
Some of the ways we protect personal information include:
- External and internal premises security
- Restricted access to personal information to staff who need it to perform their day to day functions
- Conducting training to ensure that staff are aware that they must only access, use and disclose personal information for appropriate purposes
- Requiring staff who have access to personal information to agree to protect the privacy of that information
- Maintaining technology products to prevent unauthorised computer access, including identifiers and passwords
- Maintaining physical security over paper records
How long does Noble Volkswagen keep personal information?
We will take steps as are reasonable in the circumstances to destroy the information or to ensure that the information is de-identified.
Use of Government related identifiers
We will not use Government related identifiers as our own identifier of individuals. The use or disclosure of these identifiers will be restricted to that permitted by the Privacy Act.
Transfer of personal information overseas
If Noble Volkswagen transfers your personal information outside Australia, we will comply with requirements of the Privacy Act that relate to cross-border data flows. Please note that some of the servers on which Volkswagen Australia's customer information is held are located overseas. As a result, personal information collected and held by Volkswagen Australia may be transferred overseas to be held on these servers.
Access to personal information by individuals
Please contact Noble Volkswagen if you would like to access or correct the personal information that we hold about you. We will generally provide you with access to your personal information. Depending on the amount of information requested, Noble Volkswagen may charge an access fee to cover the cost of retrieving the information and supplying it to you.
Access to personal information may be refused in accordance with APP 12 in a number of circumstances, for example where the information relates to anticipated legal proceedings or the request for access is deemed by us as frivolous or vexatious. If we deny or restrict your access, we will explain why. Similarly, in some limited circumstances we may not make requested corrections to personal information, in which case we will provide you with reasons for this decision.
Job applicants and employees
Any personal information provided to Noble Volkswagen in connection with job applications may be used to consider the applicant for current and future employment and may be disclosed to our third party advisors to assist us in the selection and recruitment process.
If your application for employment is successful, Noble Volkswagen will rely on the exemption in the Privacy Act relating to employee records where applicable.
Resolving concerns
If you have any concerns about the way your personal information is managed by Noble Volkswagen, or believe that a breach of your privacy has occurred, please contact Noble Volkswagen. We will respond to your concerns as soon as possible.
Changes to this policy
We may amend this policy from time to time at our discretion. Amended versions will be posted on our website at www.noblevolkswagen.com.au or mailed on request.