PFG Australia – Privacy Policy
1.1 GENERAL
PFG Australia Pty Ltd (‘PFG’ or ‘We’) are committed to protecting your privacy, in accordance with applicable Australian privacy laws.
This Policy is designed to give you a greater understanding of how we collect, use, disclose and otherwise handle personal information.
A copy of this Privacy Policy is available on our website at www.pfgaustralia.com.au/privacy or you can request a copy by contacting our Privacy Officer (details under paragraph 12 below).
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. Examples include your name, address, date of birth and email address.
2. WHAT WE COLLECT
2.1 GENERAL
The types of information that we collect about you, your products or any devices you use to connect with PFG may differ depending on your dealings with us (such as whether you are our customers, dealers, partners, officers or employees. Such information may include the following:
-payment details including credit card details for the purpose of processing your payment;
-information about your product (such as make, model, servicing dealer, date of purchase and diagnostic information);
-information from your connected devices (such as how you interact with our website, products, services);
-demographic information (such as gender, date of birth);
-commercial information (such as your business name, business address);
-your contact information such as telephone numbers, email addresses;
-if you send us an enquiry or provide us with feedback, we may collect your name, contact details, details of your enquiry or feedback and information about our response;
-if you apply for a job with us, we may collect the information you include in your job application, including your cover letter, resume, contact details and referee reports; and
-If you apply to be our dealer, or is associated with an applicant, we may collect the information you include in the application, including name and contact details, and financial information, and commercial credit report information that we obtain from our credit report information providers.
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.
2.3 COLLECTION OF INFORMATION OTHER THAN PERSONAL INFORMATION THROUGH OUR WEBSITE
When you visit our 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, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.
We use and disclose this information in anonymous, aggregated form only, for purposes including statistical analysis and to assist us to improve the functionality and usability of our website. You are not individually identified; however, we reserve the 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
A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users, although they do identify the user’s internet browser.
We use cookies to hold anonymous session information. This information is used to personalise your current visit to the website, for example to allow the website to remember who you are by keeping server variables linked to your session.
We only use non-persistent cookies. That is, they are held on your browser’s memory only for the duration of your session.
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. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website.
Online Behavioural Advertising
We use 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 clicking here.
Connecting with us
If you log into PowerLink via our website, we will collect your name and contact details for use in transactions between you or your business and us.
If you connect with us on Facebook, we will collect your name. We will also have access to any of the information that you publish on Facebook, subject to your personal privacy settings.
2.4 WHAT IF YOU DON’T PROVIDE US WITH YOUR PERSONAL INFORMATION?
We will provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to an individual’s actual name.
For example, you can access our website and make general phone queries without having to identify yourself.
In some cases, however, if you don’t provide us with your personal information when requested, we may not be able to provide you with the product or service that you are seeking. For example, you must identify yourself to open a dealer trading account.
If you do not provide us with the personal information described above, some or all of the following may happen:
-we may not be able to register your product warranty with us;
-we may not be able to assess your application for employment with us;
-we or our PFG dealers may not be able to provide you with information about products and services that you may want, including information about discounts, sales or special promotions;
-certain features of our website may not function properly;
-we may be unable to tailor the content of our websites to your preferences; or
-we may be unable to process your dealership application or open a dealer trading account.
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, such as at conferences and events)
-through one of our websites (for example pfgaustralia.com.au, or howard-australia.com.au)
-through our Facebook and other social media presence
-over the telephone
-through written correspondence (such as letters, faxes and emails)
-on hard copy forms (for example, competition entry forms and surveys)
-through the tractors, machinery and other products you use; and
from third parties, including:
–when you finance a vehicle through our finance partner (PFG Credit), we may collect personal information about you from PFG Credit after the finance is completed;
–when you apply to be our dealer, we may obtain commercial credit report information from our commercial credit report information provider so that we can assess your application;from your dealer who has provided us with your personal information so we can provide a service, such as a warranty service to you; and
-from government information services such as the public registers maintained by the Australian Securities and Investments Commission.
3.2 COLLECTION NOTICES
Where we collect personal information about you, we will take reasonable steps to provide you with certain details about that collection (such as the purpose for which we are collecting the information and the type of third parties to which it is usually disclosed). We will generally include this information in a collection notice.
Collection notices provide more specific information than this Privacy Policy. The terms of this Privacy Policy are subject to any specific provisions contained in collection notices and in the terms and conditions of particular offers, products and services. We encourage you to read those provisions carefully.
3.3 UNSOLICITED INFORMATION
Unsolicited personal information is personal information we receive that we have taken no active steps to collect (such as an employment application sent to us by an individual on their own initiative, rather than in response to a job advertisement).
We may keep records of unsolicited personal information if the Privacy Act permits it (for example, if the information is reasonably necessary for one or more of our functions or activities). If not, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.
3.4 INFORMATION FROM DEALERS
If you are a customer of a dealer and you have given your details to the dealer for the purposes of customer care, such as a product enquiry or a warranty claim, then the dealer may provide that information to us so we can provide the customer care to you.
4. WHY WE COLLECT PERSONAL INFORMATION
4.1 GENERAL
The main purposes for which we collect, hold, use and disclose personal information are set out below:
-to facilitate and process resolution of warranty clams;
-to analyse and improve the performance of our services and products, identify potential safety issues and implement necessary safety recalls;
-to help us determine whether we should enter into a commercial relationship with you;
-managing our relationship with the people who deal with us, including suppliers and dealers;
-promoting ourselves and our products and services, including through direct marketing, events and competitions (see under paragraph 4.2 below);
-obtaining products and services for our business;
-performing research and statistical analysis, including for customer satisfaction and product and service improvement purposes;
-protecting the security of our offices, staff, customers and the property held on our premises;
-answering queries and resolving customer complaints or providing customer support;
-to customise and improve communication content;
-for warranty administration and validation; and
-recruiting staff and contractors.
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; or
-for which you have provided your consent.
4.2 DIRECT MARKETING
We may use or disclose your personal information to let you know about us and our products and services (including promotions, special offers and events), either where we have your express or implied consent, or where we are otherwise permitted by law to do so. We may contact you for these purposes in a variety of ways, including by mail, email, SMS, telephone, online advertising or facsimile.
Opting out
Where you have consented to receiving marketing communications from us, your consent will remain current until you advise us otherwise. You can opt out at any time, by:
-contacting us (details under paragraph 12 below)
-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 electronic messages (such as emails, SMS messages and MMS messages)
Notification of source
If we have collected the personal information that we use to send you marketing communications from a third party (for example a direct mail database provider), you can ask us to notify you of our source of information, and we will do so, unless this would be unreasonable or impracticable.
5. WHO WE MAY SHARE YOUR PERSONAL INFORMATION WITH
We may share personal information with third parties where appropriate for the purposes set out under paragraph 4, including:
-with your local dealer for the purpose of answering your queries and providing goods and services to you;
-financial institutions for payment processing;
-your agent or authorised representative;
-referees whose details are provided to us by job applicants;
our contracted service providers, including:
-delivery and shipping providers;
-information technology and data storage providers;
-venues and event organisers;
-marketing and communications agencies;
-research and statistical analysis providers;
-call centres;
-mail houses;
-external business advisers (such as consultants, recruitment advisors, accountants, 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.
6. CROSS BORDER DISCLOSURE OF INFORMATION
We may disclose personal information to our parent company in New Zealand and, if it is necessary to be able to provide services to you, to a supplier of ours in connection with a product that you have acquired or are considering acquiring.
In each case, we will comply with the requirements of the Privacy Act that apply to cross border disclosures of personal information.
8. COMMERCIAL CREDIT PRIVACY
8.1 HOW DO WE COLLECT FOR CREDIT PURPOSES?
We may collect commercial credit information in connection with an application to open a trade account with us as a dealer.
8.2 WHAT COMMERCIAL CREDIT INFORMATION DO WE COLLECT FOR CREDIT PURPOSES
We collect the names and contact information of:
-applicants who are sole traders
-the partners of applicants that are partnerships
-the directors of applicants that are corporations.
We collect the financial information about the applicants. We may collect commercial credit information of the applicants (and if applicable, the applicant’s partners and directors) from credit reporting bodies, including commercial credit reports. A commercial credit report may include information about your credit worthiness.
8.3 HOW DO WE USE COMMERCIAL CREDIT INFORMATION COLLECTED
We may use the information that we collect from you and from credit reporting bodies to assess your application for a credit account by a dealer or assess the application for a credit account of a partnership dealer in which you are a partner or a company dealer of which you are a director. To the extent permitted or required by law, we may also disclose the information that we hold to notify other credit providers of a default of the credit obligations by the dealer to us or exchange information with another credit provider when the dealer is in default of your credit obligations to the other credit provider.
9. DATA QUALITY AND SCREENING
9.1 GENERAL
We hold personal information in a number of ways, including in electronic databases, email contact lists, and in paper documents held in locked drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. We take reasonable steps to:
-make sure 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; and
-destroy or permanently de-identify personal information that is no longer needed for any purpose 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.
9.2 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 our computer systems (such as login and password protection), controlled access to our corporate premises, policies on document storage and security, personnel security (including restricting access to personal information on our systems to staff who need that access to carry out their duties), staff training and workplace policies.
Website security
While we endeavour 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 us by telephone or post (details under paragraph 12 below).
If you are a registered PowerLink user, you can also help to protect the privacy of your personal information by maintaining the confidentiality of your username and password and 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.
10. ACCESS & CORRECTION
10.1 GENERAL
Please contact our Privacy Officer (details under paragraph 12 below) if you would like to access or correct the personal information that we hold about you. We may require you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.
10.2 ACCESS
We will generally provide you with access to your personal information, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (e.g. by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information, we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
If we correct personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, we will take reasonable steps to do so, unless this would be impracticable or unlawful.
10.3 TIMEFRAME FOR ACCESS AND CORRECTION REQUESTS
Except in the case of more complicated requests, we will endeavour to respond to access and correction requests within 30 days.
10.4 WHAT IF WE DO NOT AGREE TO YOUR REQUEST FOR ACCESS OR CORRRECTION?
If we do not agree to your access or correction request, or if we do not agree to give you access in the manner you requested, we will provide you with a written notice setting out:
-the reasons for our decision (except to the extent that, having regard to the grounds for refusal, it would be unreasonable to do so); and
-available complaint mechanisms.
In addition, if we refuse to correct personal information in the manner you have requested, you may ask us to associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, and we will take reasonable steps to do this in such a way that will make the statement apparent to users of the information.
11. COMPLAINTS
If you have a complaint about how we have collected or handled your personal information, please contact us (details under paragraph 12 below).
We will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week. If we are not able to do so, we will ask you to submit your complaint in writing.
In most cases, we expect to investigate written complaints and provide a response within 30 days of receipt. If the matter is more complex and our investigation may take longer, we will contact you and tell you when we expect to provide our response.
If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner (see here for further information).
12. OUR CONTACT DETAILS
Please contact us if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details are set out below.
Mail: PFG Australia Privacy Officer, 199 Australis Drive, Derrimut, Victoria 3026
Email: privacy@pfgaustralia.com.au
Telephone: +61 3 8353 3600
Further general information about privacy is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au or by calling the OAIC’s enquiry line at 1300 363 992.
13. CHANGES TO THIS PRIVACY
We may amend this Privacy Policy from time to time. The current version will be posted on our website and a copy may be obtained by contacting our Privacy Officer (details above).