Privacy Policy This privacy policy (“Policy”) sets out how the Keema Automotive Group (“Keema”) uses and protects the personal information that you give Keema when you use its website, complete application forms, or provide personal information in respect to a transaction with us.

Keema is bound by, and will comply with, the Australian Privacy Principles (“APPs”) set out in the Privacy Act 1988 (Cth) (“Act”).

Keema is committed to ensuring that your privacy is protected and has implemented practices, procedures and systems relating to the protection of your personal information, including this Policy which explains what kind of information we may gather about you when you visit our site or interact with our products and services and how we may use, store and manage that information. The Policy also provides details about the disclosure of your personal information, and your ability to access and correct this information or make a complaint. Should we ask you to provide certain information when you are dealing with us, you can be assured that it will only be used in accordance with this Policy.

What and how do we collect Personal Information

Keema only collects personal information by lawful and fair means and not in an unreasonably intrusive way. Where it is reasonable or practical to do so, we will only collect information about you from you. Personal information is collected by Keema, when you access and use our website, apply for finance to acquire a vehicle, purchase a product or service, or enter into a promotion.

If we receive unsolicited information about you, we will check to determine whether that information is necessary in relation to our business and the services and products we supply to you. If it is necessary, we will use and manage the information in accordance with this Policy. If it is not necessary, we will either destroy the information or de-identify it.

The sort of personal information that we may collect and hold includes:

• Contact information including your name, address, telephone, fax number and email address>
• Financial information including your bank account details or credit card and tax file number or other billing details. If you are acquiring a vehicle in the name of a company, the company details and your job title.
• If you hire a car, your driver’s licence number.
• We may also collect personal information as required or authorised to be collected by law.

Keema does not collect sensitive information, which is information about any individual’s racial or ethnic origin, political opinion and association, religious or philosophical beliefs, professional, union or trade association, sexual practices, criminal record or health information.

What we do with the information we gather

We require this personal information so that we can provide you with our products and services and so we can understand your needs and provide you with a better service. Banking and finance companies may require your personal information in order to determine whether they will provide you with finance. Manufacturers’ may require your personal information to register or process a warranty or a warranty claim on your behalf or to analyse the results of the delivery of its products.

We may also be required to disclose information about you by law or under a court or tribunal order; or in connection with an actual or prospective legal proceeding; or to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk). We may also need to disclose your information to a prospective purchaser of any business or asset which we are or may sell.

Except as provided in this Policy, we will not use or provide your information to a third party for any other purpose (a ‘secondary’ purpose), except if:

• You have consented or would reasonably expect that we would use or disclose the information for secondary purpose, and that purpose is related to why we originally collected your information; or
• t is required or authorised by or under an Australian law or an order given by a court or tribunal or to establish, exercise or defend a legal or equitable claim or for an alternative dispute resolution process; or
• We suspect that in relation to our business an unlawful activity or misconduct of a serious nature is being engaged in, and the information is required as part of our investigation; or is necessary for an enforcement body to prevent, detect, investigate, prosecute or punish criminal offences, breaches or the enforcement of certain laws; or
• It is necessary to locate a missing person, or lessen or prevent a serious threat to an individual’s life or the health or safety of the individual or the public, and it is unreasonable for impracticable to obtain the consent of the individual whose personal information is to be disclosed; or
• Where we collect your tax file number for the purpose of obtaining finance we will not use or disclose this information unless there is a suspicion that an unlawful activity is being engaged in, or the disclosure of the information is required or authorised by an Australian law, or a court or tribunal order.

Direct marketing

From time to time, we may use your information for market research purposes to customise our website or to send you information including newsletters, invitations, new products, developments and special offers or other information which we think you may find interesting by using the contact details (either telephone, email, mail or SMS) you have provided only if:

• We have collected the information from you and you reasonably expect us to use or disclose the information for direct marketing activities, and you have not asked us to stop providing you this marketing communication; or
• We have collected the personal information for direct marketing activities from either you or someone else with your permission or it is impracticable to obtain your consent. Although we have made it clear in our marketing communications to you that you may opt out of receiving this marketing communication, you have not done so.

When completing application forms or entering into competitions or communicating with financiers’ or manufacturers’ they may use your personal information for direct marketing if you consent to that use. You may decline to have your personal information used in this manner.

We will not without your express consent provide your personal information to any other third party for the purpose of direct marketing. Even if you have previously agreed that we can use your personal information for direct marketing purposes, you may change your mind at any time by contacting us. Please see the contact details at the end of this Policy.

How we use cookies

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites. We do not have any control over other websites and therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites.This Policy does not apply to those websites. Those website owners are responsible for the privacy of the information they collect and should be contacted directly for details of their privacy policies.

Notification

At or before the time that we collect personal information from you, or as soon as practicable after, we will take all reasonable steps to ensure that you are aware of:

• Our identity and how to contact us, access and seek correction of personal information and how to make a complaint in relation to our compliance to the Act and the APP’s.
• The purpose for which the information is collected. Whether there is any law or court or tribunal order that requires the particular personal information to be collected and the consequences (if any) for the individual if the information is not provided.
• Who we would usually disclose the personal information to, including whether disclosure is likely to be made to overseas recipients.

We will also take reasonable steps to ensure that you have been made aware of the matters listed above, even though we may have collected the personal information about you from someone else, unless in our opinion making you aware of these matters would pose a serious threat to the life or health of anyone.

Anonymity

You are permitted to use an anonymous name or pseudonym when dealing generally with us. However, you will not be able to be anonymous or use a pseudonym where it is impracticable to deal with you, or if we are required by law, or under a court or tribunal order to only deal with those who have identified themselves

Information to people and organisations located overseas

We will not provide your personal information to someone or to another organisation in a foreign country unless we have taken reasonable steps to ensure that the information which is intended to be disclosed will not be held, used or disclosed by the recipient inconsistently with the APP. However, we are not obligated to ensure that the overseas recipient does not breach the APP, where:

• We reasonably believe that the recipient is subject to a law, or binding scheme that is at least substantially similar to the way that the APP protects information and there are mechanisms that you can access to take action to enforce that protection; or
• You expressly consent to the disclosure even after we have informed you that our obligation to take reasonable steps to ensure that the overseas recipient does not breach the APPs no longer applies; or
• Disclosure is required or authorised under an Australian law, a court or tribunal order, or is required to assist locate a missing person, or to lessen or prevent a serious threat to the life, health or safety of any individual or to public health or safety, or necessary to take action in relation to the suspicion of unlawful activity or misconduct of a serious nature that relates to Keema’s activities.

Security

We are committed to ensuring that your information is secure and protected from misuse, interference, loss, unauthorised access, modification or disclosure, and accordingly, we have put in place physical, electronic and managerial procedures and systems to safeguard and secure the information that we collect.

We have a strict and secure environment. We have adopted security measures to prevent unauthorised entry and access to our premises and to the computer systems, networks and files. Keema’s systems contain firewalls to prevent outside access, interference or modification and all files and records are maintained in a strict secure environment with only those individuals who have a need to know your personal information having access to the information.

What happens to information that is no longer required by us

Where the personal information is no longer required by us, we will either destroy or permanently de-identify it using secure means. The information will not be destroyed or de-identified if it is required to be retained by us under an Australian law, or an order given by a court or tribunal.

Controlling your personal information

You may access the personal information that we hold about you, except if:

• Frivolous:the request is frivolous or vexatious;
• Unlawful: providing access would be unlawful;
• Privacy or safety: it would have an unreasonable impact upon the privacy of others; or would pose a serious threat to the life, health or safety of any individual or a threat to public health or safety;
• Prevented by under law: we are required to deny access under law, or a court or tribunal order or if the access would be likely to prejudice enforcement related activities conducted by or on behalf an enforcement body; or
• Unlawful activity: we suspect that there is an unlawful activity or misconduct of a serious nature that relates to our business, and if providing access would prejudice an investigation, negotiation or a proceeding between us and you in which the information would not be accessible by discovery.

Where we cannot provide you with access to the information, then we will, if it is reasonable to do so, consider whether an intermediary would allow sufficient access to meet both our needs.

We reserve the right to charge you reasonable costs for providing access to your personal information. You will be notified of these costs prior to providing you access to the information. These fees and charges will not be excessive and will be determined by us from time to time and may be required to be paid prior to providing you with access.

Correcting your personal information

If you believe that any information we are holding on you is incorrect, incomplete, not up to date, irrelevant or misleading, please contact us as soon as possible at the details below. We will, after considering the purpose for which the information is held, take reasonable steps to correct any errors and if practicable notify any third parties that Keema had previously disclosed the information to of the correction. If we consider that the information does not need to be amended we will, at your request, keep with your personal information a statement apparent to users of the information noting your request that the information should be modified.

If at any time we refuse or deny you access to information or refuse to correct your information we will provide you with reasons for such denial or refusal and the mechanisms available to you to complain.

Queries, complaints or concerns regarding your personal information

If you have a complaint about how we have used or disclosed your personal information, then you may contact us via our interactive website, or via email on privacy@keema.com.au or by phone on 1300 766 609.

Updates to the policy

We may update this Policy from time-to-time by posting a new version on our website. You should check this website occasionally for the latest Policy.