Privacy Policy

Last updated on 7 November 2022

This Privacy Policy applies to Global Cars Aus Pty Ltd doing business as "SpareChange Used Cars" and “Cars24” (ABN 22 645 541 920) and each of its Australian related bodies corporate from time to time, together referred to in this Privacy Policy as Cars24, us or we.

Cars24 is committed to protecting your Personal Information. Cars24 complies with the Privacy Act 1988 (Cth) (Privacy Act) Privacy (Credit Reporting) Code 2014 (Version 2.2) (Credit Reporting Code)and regulations thereunder (together, the Privacy Laws) in the collection, storage, transfer, processing, retention and deletion of the Personal Information that we collect from users of our services (you, your).

Cars24 acts in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act. The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. You can view the APPs on the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au.

We will also handle your Credit-related Information in accordance with Part IIIA of the Privacy Act and the Credit Reporting Code

This Privacy Policy applies to the Personal Information (including Credit-related Information) collected by Cars24 in the course of your use of our services or via the Cars24 website (our website) and our related services. It also describes your rights regarding the use, access and correction of your Personal Information.

1. What is Personal Information and Credit-related Information?

'Personal Information' is information or an opinion about an identified individual, or an individual who is reasonably identifiable:

whether the information or opinion is true or not; and
whether the information or opinion is recorded in a material form or not.

'Credit-related Information' is a type of personal information that includes the following:

Credit information means personal information we collect in connection with a credit application, including information that identifies you, the amount you've borrowed, repayments, defaults and bankruptcy.
Credit reporting information is credit information or information derived by a credit reporting body from credit information used for assessing eligibility for consumer credit, such as a credit score or credit report.
Credit eligibility information is your credit reporting information provided to a credit provider, and any further information a credit provider derives from this information that has any bearing on your creditworthiness and could be used in establishing your eligibility for consumer credit

2. What types of Personal Information do we collect from you and how do we collect it?

We only collect Personal Information to the extent that it is reasonably necessary for one or more of our functions or activities. Examples of the Personal Information that we may collect include:

contact details including your name, address, email address and phone numbers;
where required, identification information including date of birth, driver's licence, driver's licence number and registration certificate (in relation to the person who owns the vehicle, including family members), photographs at point of delivery;
if you apply to purchase a vehicle, we may collect or receive information from our third party providers including Credit-related Information and other financial information (such as credit score, lender and loan information, reasons for decline, interest rate, boarding, residency and employment status, contact details, home ownership status);
if you apply for finance for your vehicle through us, or are a potential guarantor on an application for finance, we may collect Credit-related Information about you from you and from credit reporting bodies including your credit history (such as the type of credit you have, how much you have borrowed, if you've made repayments and if you've experienced financial hardship), credit report, creditworthiness information, whether you have committed fraud or other serious credit infringement and obtaining commercial credit information about you in order to assess an application by you for consumer credit;
for payment processing, our third party providers may process your credit card information and bank details (see paragraph ‎‎7 below);
if you apply for a job with us, we may collect your contact details, right to work information, location, police and background check information (with your consent), employment references and information related to your application such as notice details, salary expectations, qualifications and ability;
if you attend our premises, we may collect health information including medical history or vaccination information (with your consent).

This Personal Information is obtained in many ways including from our third party providers and public searches, interviews, correspondence, by telephone, by email, via our website, from media and publications, from social media, from other publicly available sources, from cookies and from third parties.

When you use our services or visit our website we may automatically collect information about your computer hardware and software, including your IP address, browser type, domain names, internet service provider, the files viewed on our site (e.g. HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Cars24 to provide general statistics regarding use of our website. For these purposes, we may link this automatically-collected data to Personal Information such as name and email address.

3. We do not collect Sensitive Information about you without consent

We do not collect Sensitive Information about you (as defined in the Privacy Act), unless you provide it to us voluntarily, or consent to its collection. ‘Sensitive Information’ includes information or opinion about an individual’s racial or ethnic origin, political opinion, religious beliefs, sexual orientation or criminal record, as well as health information and certain genetic and biometric information, provided that the information or opinion otherwise meets the definition of Personal Information. In some cases, certain Sensitive Information may be requested as part of a job application, or your role as our contractor or employee (such as vaccination information).

You consent to us collecting Sensitive Information which you provide to us voluntarily, for the purposes that information was collected. If we need to collect any Sensitive Information for a specific purpose, we will ask for your specific consent and only use or disclose that information for the purposes it was collected, or as otherwise permitted under the Privacy Act.

4. Personal Information collected from other sources

If you provide us with Personal Information relating to any other individual, you should ensure that you have obtained the consent of that individual to provide us with such Personal Information for the purposes set out in this Privacy Policy. This includes information about a family member or other member of your household that may be included in an application or be listed on a vehicle registration.

If someone other than you provides us with Personal Information about you that we did not ask for, or you provide us with unsolicited Personal Information, we will only hold, use or disclose this information if we determine that we could have collected this information from you had we asked for it. In this circumstance, we will take all reasonable steps to notify you of the collection of that information. If we could not have collected this Personal Information, we will de-identify or destroy that Personal Information as required by law.

5. Security of your Personal Information

We hold your Personal Information in different ways, including in paper and electronic form. All Personal Information that we collect is protected using appropriate physical, technical and organisational measures and is restricted to our authorised staff on a strict need-to-know basis. We take reasonable steps to secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. In appropriate cases, we require our external service providers with access to Personal Information to sign data processing agreements or similar agreements that require them to take the necessary and reasonable steps to protect the Personal Information provided to them.

Despite these reasonable steps, no security system is impenetrable and, due to the inherent nature of the internet, we cannot guarantee that information, during transmission through the internet or while stored on our systems or otherwise, will be absolutely safe from unauthorised access by others.

6. How do we use your Personal Information?

Our use of your Personal Information will depend on our relationship with you, the circumstances of collection and the types of products and services you request from us. Groups of individuals that we collect information about may include the general public who visit our website, our customers, contractors, job applicants and business contacts of our service providers..

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:

provide you with products and services;
update and maintain our records;
conduct identify verification, where required by law;
protect, improve and develop our products and services, including by performing analytics and conducting research;
assess your suitability for consumer or commercial credit as a borrower or guarantor, on behalf of a credit provider;
send information or content to you which we think may be of interest to you by email, or other means and send you marketing communications and retargeting on advertisement platforms relating to our business;
promote use of our products and services to you and share promotional and informational content with you in accordance with your communication preferences;
administer rewards, surveys, contests, or other promotional activities or events;
send information to you regarding changes to our customer agreement terms, website terms or this Privacy Policy;
sharing information with our service providers and suppliers, including seeking warranty information and providing customer details to original equipment manufacturers (OEMs) of vehicles that are sold;
where you are a contractor, for purposes related to your role with us, our management of your services and the performance of services by you;
where you apply for a role with us, to assess your suitability for a role;
conduct any internal management purposes, including any merger or sale of our business (as described in paragraph ‎‎‎7); and
comply with our legal obligations, conduct dispute resolution and manage our agreements with third parties.

We may disclose Personal Information in accordance with the applicable law and for the purposes described above, including to third parties such as our contractors, suppliers, agents, third parties and service providers who help us deliver, administer and support our products and services, including for the purposes set out under paragraph ‎‎6). We may also share your personal data with third parties to fulfil any request made by you with respect to any service or product. Third parties with whom we have shared your data may contact you directly or through us to provide you with the services being offered by them on an independent basis.

We may use and disclose your Personal Information for the primary purpose for which we have collected that information, for related secondary purposes within your reasonable expectations, where permitted under the Privacy Act and where otherwise required or authorised by law, including under the Privacy Act.

If we act as an agent for a credit provider, we require Credit-related Information to assess your credit, or guarantor, application or the credit application of a company of which you are a director, to source a suitable credit provider and any required insurances and to manage the application process, where required.

7. Who do we disclose your Personal Information to?

verifying identity, including third party identity verification services;
delivering our products and services;
registering your vehicle, and/or transferring the registration of your vehicle with the Victorian Department of Transport;
hosting our servers and website;
conducting credit checks and assessing creditworthiness;
conducting data analysis, research and surveys;
direct marketing and sales initiatives, including third party email, SMS and marketing platforms and providers;
data processing, storage and back-up; and
processing payments.

We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your Personal Information.Disclosure to our service providers

We engage other entities to provide services to our customers and other users and may need to share your Personal Information with them to provide information, products or services to you. Examples may include analysing data or performing statistical analysis, supplementing the information you provide us in order to provide you with better products or services and providing support. In all cases where we share your Personal Information with such entities, we explicitly require them to acknowledge and adhere to our privacy and data handling policies.

Some of the key third party service providers we use include financing services (Driva), payment processors (Stripe and POLi), email marketing and messaging (Mailchimp, Hubspot, Clevertap), identity verification (GBG and government identification services), support (Zendesk), e-signing (DocuSign) and other services. We may update or change the service providers that we use from time to time and will continue to take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your Personal Information. In some instances, you will be asked to provide information directly to these providers, in those cases Personal Information will be handled in accordance with the third party service provider's terms and conditions and privacy policies.

Disclosure for the purposes of corporate transactions

If our business is acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information (including Personal Information) held by Cars24 that had been gathered by use of our services or through the use of our website. If this information includes your Personal Information, you will be notified via email or a prominent notice on our website, of any such change in ownership, the uses of your Personal Information, and choices you may have regarding your Personal Information.

Disclosure to Victoria's Department of Transport

We represent the Secretary of the Victorian Department of Transport in collecting and providing it with information about individuals which is required to register vehicles, including the individual's name and address. If you would like to contact the Department, please see the latest contact details on its website here.

Compelled disclosure

We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

8. International transfers of Personal Information

Some of the third parties we disclose your Personal Information to may be based or have servers located overseas. You should note that disclosures may occur in countries other than those referred to in this Privacy Policy from time to time. Before we disclose your Personal Information to an overseas recipients, we will take all reasonable steps to ensure that your Personal Information is only processed for authorised purposes and adequately protected using the appropriate technical, organisational, contractual or other lawful means. You consent to us disclosing your Personal Information to overseas recipients on this basis.

Cars24 is based in Australia and our headquarters are in India. Some of our operations may be conducted in India or other locations by our related companies and this may involve use or disclosure of your Personal Information to those related companies or their service providers. Any Personal Information you provide us may be transferred from your country of origin to Australia. Cars24 also has arrangements with third party hosting providers based offshore and the Personal Information that we collect from you may be stored in the offshore servers of such third party providers. These third party providers may be located in a range of locations outside Australia, including India, but due to the nature of cloud services it is impractical to specify these locations in advance. As part of the steps we take to protect your Personal Information, we require appropriate contractual and security safeguards in the arrangements with such providers, including where Personal Information is stored outside of Australia.

9. How to exercise your rights in relation to your Personal Information

Under the Privacy Laws, you have certain rights in relation to the Personal Information that you provide us including:

you can request access to or correction of your Personal Information (including Credit-related Information);
if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect use or disclosure of your Personal Information conducted in reliance on grounds other than consent; and
the right to complain to us about how we have handled your Personal Information and Credit-related Information, if you believe we have breached the Privacy Laws (see Section 20 below); and
you have the right to complain to The Office of the Australian Information Commissioner about our collection and use of your Personal Information (including Credit-related Information) – see Section‎20 below.

To exercise any of these rights, please contact us using the contact details in Section 21 below. We will respond to your request to access or correct your information within a reasonable timeframe and notify you of the action we have taken.

Access to your Personal Information

There may be instances where we cannot grant you access to the Personal Information and Credit-related Information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal. There is no charge for requesting access to your Personal Information but we may require you to meet our reasonable costs in actually providing you with access.

Accuracy of your Personal Information

We will take all reasonable steps to ensure that the Personal Information and Credit-related Information we collect, use or disclose is accurate, complete and up-to-date, and we will try to confirm your details through our communications with you and promptly add updated or new Personal Information to existing records when we are advised. However, we rely on the accuracy of Personal Information as provided to us both directly and indirectly. If you believe we are holding Personal Information about you that is inaccurate, incomplete, irrelevant or misleading, you can ask us to correct it, or delete it altogether. We will respond to your request within a reasonable period and if we do not consider that your Personal Information needs correcting, we will provide reasons for the refusal and information about how you can complain about the refusal.

To unsubscribe from our communications

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our emails, updating your communication preferences, or by contacting us at the details below. You cannot opt-out of receiving transactional emails related to your account with us, such as updates to your customer agreement terms or this Privacy Policy.

10. How long do we keep your Personal Information

We retain Personal Information and Credit-related Information that you provide to us where we have an existing purpose to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

When we have no ongoing purpose to hold your Personal Information and Credit-related Information, we take reasonable steps to securely delete the information or anonymise it or, if this is not possible, securely store your Personal Information and Credit-related Information and isolate it from any further processing until deletion is possible.

If you have elected to receive marketing communications from us, we retain Personal Information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Cars24 account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

11. Cookies and similar technologies

We use cookies and similar technologies (such as web beacons) to analyse trends, administer our website, track users’ movements around our website, and to gather demographic information about our user base as a whole. 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 Site. 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.

12. Social Media Features

Our website may include social media features and widgets, which may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

13. External Websites

Our website may provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to information collected by these other websites, which are subject to any privacy and other policies they may have. The privacy policies that apply to those other websites may differ substantially from this Privacy Policy, so we encourage individuals to read them before using those websites.

14. Public Forums

We may offer publicly accessible blogs. Please keep in mind that if you directly disclose any information through our public blogs, this information may be collected and used by others. We will correct or delete any information you have posted on our website if you so request, as described below.

15. Direct Marketing

We may, from time to time, send direct marketing communications to you via email, telephone, SMS, WhatsApp, Push notifications or other messaging channels about our activities and services and other material that we consider you would find interesting or useful. We may continue sending these direct marketing communications after you cease using our services, for example in relation to warranties or after-sale services. These communications will be sent in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth). If you do not wish to receive such direct marketing communications, you can always opt out. If you are receiving email communications from us, there will be a mechanism to opt out contained in each of those emails. To stop receiving other communications from us, you can contact us via any of the channels listed below.

If you choose to opt out of direct marketing communications, please note that Cars24 may still contact you and your employees for other reasonable purposes, including information that Cars24 is legally required to send, notifications of changes to Cars24 services or policies and information regarding the use, rights, benefits or obligations of users of our services.

We do not use Sensitive Information for direct marketing and we do not provide your Personal Information to other organisations for the purposes of direct marketing.

16. Credit providers

As part of providing our services to you, we may undertake tasks for a credit provider which are reasonably necessary to manage the application process. When doing so, we are acting as agent for the credit provider, with the same privacy law requirements applying to both of us.

We may submit your application to one or more credit providers. Those credit providers and their website addresses are set out in this table below.

SCHEDULE 1: CREDIT PROVIDERS
Name of credit provider	Website
First Mac	www.firstmac.com.au
Finance One	www.financeone.com.au
Pepper Money	www.pepper.com.au
Wisr Finance	www.wisr.com.au
Plenti Finance	www.plenti.com.au
AutoPay	www.autopay.com
Money3	www.money3.com.au
Greenlight Auto Finance	www.greenlightauto.finance

A credit provider, to whom we submit an application, may disclose information about you to, and collect information about you from, one or more credit reporting bodies.

The website of each credit provider contains details of each credit reporting body with which it deals and other details about information held about you, including whether that information may be held or disclosed overseas and, if so, in which countries. The websites also describe your key rights. These details may be described on the credit providers’ websites as ‘notifiable matters’, ‘privacy policy’, ‘credit reporting policy’ or ‘privacy disclosure statement and consent’, or similar.

If you are late in repaying consumer credit you have obtained or you commit a serious credit infringement, the credit provider may disclose that information to a credit reporting body.

Each credit provider's website includes information on how to contact it and how to obtain a copy of its privacy documents in a form that suits you (e.g., hardcopy or email).

Your rights

In addition to your rights under paragraph ‎9, you also have the rights to:

request a credit reporting body not to use your credit reporting information for direct marketing assessment purposes, including pre-screening.
request a credit reporting body not to release information about you if you believe you are or may be a victim of fraud

The credit reporting bodies we deal with are listed in Section ‎17 below.

17. Credit reporting bodies

The contact details for the credit reporting bodies we may deal with are listed below.

SCHEDULE 2: CREDIT REPORTING BODIES
Name	Website / email address	Telephone
illion	https://www.illion.com.au	13 23 33
Experian	www.experian.com.au	(03) 8622 1600
Equifax	www.equifax.com.au/contact	13 8332

The credit reporting bodies may share the information provided to it by us (or by the relevant credit provider), to other credit providers to assess your creditworthiness.

18. Amendments to this Privacy Policy

We periodically update this Privacy Policy to keep up to date with market expectations, technology, legal requirements and market practices. We will post any privacy policy changes on this page. We encourage you to review this Privacy Policy periodically on https://www.cars24.com.au/privacy-policy. Any revised Privacy Policy will take effect when it is published on our website and your continued use of our website or services will constitute your consent to be bound by these changes.

19. Making A Complaint

We are bound by the Privacy Laws, including the Australian Privacy Principles and, to the extent we handle Credit-related Information, Part IIIA of the Privacy Act. We take your complaints seriously and we will attempt to resolve any issues quickly and fairly. If you think that an act or practice of Cars24 has interfered with your privacy in relation to your Personal Information or Credit-related Information or if you have any questions about this Privacy Policy or our treatment of the Personal Information or Credit-related Information you provide us, please contact us by email using the details below. Please include your name, email address, telephone number and clearly describe your complaint. We will attempt to respond within a reasonable timeframe and notify you of the action we have taken, and we will keep records of your complaint and any resolution.

In respect of complaints relating to potential breaches of Part IIIA or the Credit Reporting Code, we will acknowledge your complaint within 7 days. We will investigate your complaint and where necessary, will consult with other credit providers or credit reporting bodies. We will notify you of a decision within 30 days or longer where agreed with you in writing.

20. Contact:

You may contact us to request access to or correction of your personal information or to make a complaint using the details below:
legal.au@cars24.com

C http://www.oaic.gov.au.

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