for Australia and New Zealand
IVECO Trucks Australia Limited (ACN 004 065 061) (“IVECO” “we”, “us” or “our”) is an IVECO Group N.V. company. Your privacy is important to us, and IVECO entities are subject to strict standards in relation to the handling of personal information, regardless of where those entities are located. We respect your privacy and are committed to being transparent about how we handle your personal information and keeping it safe.
Authorised IVECO dealerships (other than IVECO Brisbane) are separate and distinct legal entities from us and may well have their own privacy policies which may differ from ours and are responsible for their own privacy practices. Therefore, if you have privacy concerns that relate to an authorised IVECO dealership then please contact that dealership directly.
- the kinds of personal information and sensitive information we collect and hold;
- how you can deal with us anonymously or under a pseudonym;
- how personal information is collected and held;
- how we will keep your information secure;
- the purposes for which personal information is collected, held, used and disclosed;
- when we will use your personal information for direct marketing;
- how you may seek to access your personal information and seek its correction;
- how to complain if you believe we have breached your privacy and how your complaint will be handled; and
- the disclosure of your personal information to overseas recipients, and the countries in which those recipients are likely to be based.
If a current or past employee has any questions that relate to their employee records, then please contact IVECO’s human resource department.
1. THE KINDS OF PERSONAL INFORMATION WE COLLECT AND HOLD
The personal information that IVECO collects is reasonably necessary for and/or directly relevant to one of more of its functions and/or activities. Some examples of the types of personal information we collect include but are not limited to your:
- residential and business address;
- e-mail address;
- phone numbers;
- date of birth and age;
- employment details;
- education, qualifications, references and resumes;
- personal interests;
- registration number;
- drivers licence;
- other identification;
- banking details;
- credit card details;
- credit data;
- other financial information;
- economic, property and insurance data;
- whether you are on a sanctions list;
- current and historical vehicle information details;
- additional products and services that you may purchase or acquire from us or our authorised dealers;
- the dealer you purchased our products from or had your vehicle serviced with;
- your opinion in relation to your purchasing experience for our products and services;
- how you use your vehicle;
- details regarding the driver of the vehicle;
- telematics data in your vehicle, loan, demonstrator or press vehicles which may include but is not limited to the following (and may depend on your telematics subscription):
- machine data: including but not limited to vehicle status information (e.g. speed, position, movement, engine speed, acceleration, diagnostic data and vehicle sub system data); ECU status and informational alerts; dashboard and information including but not limited to engine lights and brake failure and gross combination mass.
- environmental data: including but not limited to ambient conditions (e.g. temperature), local weather, traffic and road information.
- utilisation data: vehicle operation, driver style evaluation, fuel usage and carbon omissions.
- your image or photograph by way of surveillance/security cameras or at promotional events;
- your voice if we record calls for quality, training and recording keeping purposes; and
- cookies and website tracking
Sensitive information is a subset of personal information and generally refers to data about your race, ethnicity, politics, religious or philosophical beliefs, professional or trade association membership, sexual preferences, health, genetics, biometric information or criminal record.
Unless required to be collected by law, generally IVECO does not collect sensitive information about you. However, there are times when IVECO will collect sensitive information for example, if you are engaged under a contract or are applying for employment with IVECO or if you choose to tell us about your health, and the results of criminal checks.
IVECO requires and will obtain your express consent prior to collecting, using or disclosing your sensitive information or if the collection is required by law.
Anonymity and pseudonymity
Where appropriate, you will have the option of dealing with IVECO anonymously or under a pseudonym. An example of this may be if you are making and initial enquiry about one of our products or services.
However, we will be unable to deal with you on an anonymous basis or under a pseudonym if we are required or authorised by a law, court or tribunal order to deal with an identified individual or it is impractical for us to deal with you if you have not identified yourself. This may prevent us from entering into agreements together.
If you do not provide your personal information, it may limit the manner in which we are able to assist or respond to you and we may not be able to provide certain products, services or employment (including but not limited to for example: warranty services, roadside assistance and capped price servicing).
HOW PERSONAL INFORMATION IS COLLECTED AND HELD
There are a few different ways that IVECO collects personal information from you that is directly related to or reasonably necessary for one or more of IVECO’s functions or activities. That is, to provide you with our products and the best possible services that we ourselves or our authorised dealers offer and to comply with our legal, regulatory and workplace requirements.
We may collect information directly from you
We collect most personal information directly from you in various ways by lawful means. These may include but will not be limited to when you:
- attend one of our premises;
- provide us with your business card or other contact details;
- fill out a form online or in one of our authorised IVECO dealerships or provide information to one of our representatives over the phone;
- pay your bill or purchase our products or services;
- use, loan or test drive our products. Vehicles that you test drive or loan from us may be fitted with telematics including anti-theft tracking technology and accordingly, we may track your location;
- utilise telematic services;
- order/purchase a product or service from us;
- join or use any of our rewards programs;
- enter a competition or promotion, register for and participate in a program or attend one of our events;
- subscribe to a mailing list;
- subscribe to a telematics subscription;
- choose to supply information to us on our websites;
- register a product for manufacturer’s warranty or service plan;
- contact or correspond with us;
- contact our customer support or assistance centres;
- when you have your vehicle serviced or repaired;
- apply to be an authorised IVECO dealer;
- arranging towing or contact third party roadside assistance service providers
- work with us as a contractor or secondee or apply for employment with us;
- complete a credit or finance application; and
- utilise/access shared computer programs or applications.
We may collect personal information from your online activity
We also collect personal information from you via our websites and microsites if you choose to enter your personal information. Please note, that any information you post or disclose on these websites may be available to other site visitors and the general public, depending on your privacy settings.
- site performance identifiers: these give us information about how our websites are used. This helps us provide you with a more user-friendly experience; and
- analytics cookies: we use these to gather statistics such as how many visitors are using our websites and what sections are most popular.
Personal information that we collect from others
Other people or entities might give us personal information about you. This includes but is not limited to personal information about you provided from:
- an authorised IVECO dealer from whom you have purchased our products;
- third party service providers;
- referees during a reference check if you apply to work for us;
- related entities or IVECO Group companies;
- Austroad’s National Exchange of Vehicle and Driver Information Systems if we are conducting a recall;
- enforcement agencies, government bodies and regulatory authorities;
- publicly available information sources, data aggregators, public databases, and social media sources;
- credit agencies if you are establishing a credit account with us;
- CNH Industrial Capital Australia Pty Ltd in relation to credit, finance, wholesale finance;
- entities like CNH Industrial Australia Pty Ltd that provide us with shared services like treasury functions;
- other CNH Industrial group companies; and
- authorised IVECO dealers, importers and distributors.
We may also buy or obtain personal information from trusted sources to help us identify people who might be interested in hearing about our products. We will take reasonable steps to make sure you know we have your personal information, how we got it and how we’ll handle it.
Insights from statistics and research
IVECO may aggregate and process personal information to generate new insights about its dealer network and customers, so we can provide you with the best possible products and service. [Margot, I have slightly reworded to cover this off for the future – feel free to delete and it can be reinserted once this actually happens]
IVECO is committed to protecting your personal information. However, whilst care is taken to protect your personal information, no data transmitted over the internet is completely safe.
We have adopted security measures to help ensure that your personal information is kept safe from disclosure, interference, loss, misuse or modification. Some of the security measures we use include:
- firewalls and access logging tools that protect against unauthorised access to your data and our network.
- secure work environments and workflow systems that prevent unauthorised access and copying of your personal information.
- secure server and closed network environments.
- encryption of data in transit.
- virus scanning tools.
- management of access privileges, to ensure that only those who really need it can see your personal information.
- ongoing training and security reviews.
The efficacy of these measures are routinely scrutinised due to ever changing security risks.
2. THE PURPOSES FOR WHICH PERSONAL INFORMATION IS COLLECTED, HELD, USED AND DISCLOSED
- Why we need to collect personal information
IVECO collects personal information from you when it is reasonably necessary for a business purpose. That means we collect your personal information for any purposes including but not limited to:
- providing you with the best possible products that we and our authorised dealerships have to offer;
- understanding you, and how we can meet your needs now and in the future;
- any purpose related to the purchase, sale, repair and loan of vehicles or parts;
- account, administration and billing;
- verifying your identity;
- developing or evaluating products;
- making the IVECO Group product range advertisements more relevant to you;
- managing our business;
- marketing, event and promotional activities and making those activities more relevant to you;
- to perform our obligations under a contract;
- assessing winners of sales, marketing, parts, excellence and other similar programs;
- to add your name to a contact lists;
- customer assistance, care, contact and information;
- managing complaints and claims and protecting our interests in case of disputes or claims;
- product warranties and roadside assistance;
- recalls and service measures;
- providing advice and support to our authorised dealers and customers;
- customer assistance;
- conducting market and workplace research;
- providing you with any digital services that you may request including telematic services;
- fulfil the activities of processing telematics data that will be processed either directly or though a related company or third party;
- maintain and improving relationships with authorised IVECO dealers, importers and distributors;
- checking sanctions lists;
- if you wish to own or already own a franchise of our goods and/or services;
- comply with our industry, legal, regulatory or workplace obligations or requirements;
- comply with anti-money laundering requirements;
- protecting our lawful interests (including but not limited to registered a security interest on the Personal Properties Securities Register) and rights of third parties;
- fulfilling the activities of the transfer of receivables as required for funding purposes by external financial institutions;
- fulfilling the activities of the assignment of receivables in the course of factoring to IVECO Group companies, external financiers, CNH Industrial Group companies;
- where permitted by a court, tribunal or the law.
We may also collect any information from you for any purpose which we inform you about when we collect your personal information or to which you have provided your consent.
- Disclosing personal information to the IVECO Group and CNH Industrial Group
We may share your personal information within the wider IVECO Group (which includes our parent company based in Italy, IVECO Group NV and its subsidiaries) and members of the CNH Industrial Group that provide services on our behalf or to us.
- Disclosing personal information to parties we work with
In our daily business, we may disclose your personal information to third parties, which include but are not limited to:
- our authorised dealers;
- contracted service providers (for example (not an exhaustive list) marketing agencies, insurers, mail houses, printers, market research companies, debt collectors, recruitment agencies, professional advisors, roadside assistance providers, cloud service providers and ICT support providers);
- related companies which include but are not limited to IVECO Group NV;
- companies part of the CNH Industrial group that provide services to us; and
- as required by a court, enforcement authority, law, regulator or tribunal.
IVECO works with third parties to provide sales, business and customer support, finance and insurance. These third parties may have access to systems that include your personal information. These companies are subject to strict controls that protect your information from unauthorised use or disclosure and limit their access to your personal information to the extent necessary to do their job.
- Assignment of receivables and outstanding payments
In some circumstances, IVECO may assign its receivables for funding purposes (e.g. to CNH Industrial Capital Australia Pty Ltd (ACN 069 132 396); or it may need to refer or sell overdue debts to debt collectors or other companies. If we do this, we’ll give them secure access to the personal information they need to handle the debt. We may also update credit reporting agencies about some types of payment defaults, although we’ll always tell you before we do this.
- Legal obligations and other privacy exceptions
IVECO gives access to personal information where we are permitted or obliged to do so by Australian law. For example, we will use or disclose personal information to react to unlawful activity, serious misconduct, or to reduce or prevent a serious threat to life, health or safety. We are obliged to cooperate with law enforcement bodies. IVECO may disclose personal information if we receive a request, subpoena, warrant (or the like) that authorises the disclosure under Australian law.
In the event of a safety recall, IVECO may provide your personal information to the relevant government agencies, authorities and regulators.
- Direct marketing
IVECO may use your personal information to send you advertising in relation to our products or services that are targeted to your interests, characteristics or general location. We may directly market to you though a variety of channels including telephone, SMS, e-mail and online advertising. This doesn’t necessarily mean you’ll get more advertising. It just means that the advertising that you see will hopefully be more relevant to you.
We will obtain your consent prior to using or disclosing your personal information for direct marketing purposes and you will be able to opt out at any time of marketing by following the relevant prompts or by calling us.
From time to time, you may be contacted solely in relation to your satisfaction in relation to the purchase of a product or service. This contact is not direct marketing as we are not trying to advertise or promote our goods or services. However, if you do not wish to be contacted, we will respect your wishes.
- Electronic communications
If we communicate with you electronically (for example, by instant messaging, SMS/IMS/MMS and other mobile messaging (but excluding voice to voice communications), our direct marketing complies with the Spam Act 2003 (Cth) and The Unsolicited Electronic Messages Act 2007 (New Zealand) as amended from time to time. We take steps to ensure that our direct marketing electronic communications:
(a) are only sent with your consent, which you provide expressly, or in limited circumstances if your consent is inferred by your conduct or an existing ongoing business relationship;
(b) contain accurate information about us and how to contact us; and
(c) contain a functional unsubscribe facility to allow to you to opt out for receiving future electronic messages from us. Though you are always free to contact us, and opt back in at any time.
To opt out of receiving most telemarketing calls if you have a telephone number that is primarily used for domestic or private purpose you can register it on the Do Not Call Register Act 2006 (Cth) or equivalent in New Zealand. If you have registered your number on the register unless you have expressly opted in to receive direct marketing phone calls from us, we will not contact you. Of course if you have opted in for us to contact you by phone for direct marketing purposes, you can opt out at any time.
We will still contact you for the following purposes which are not telemarketing purposes:
- product recall and fault rectification calls;
- appointment rescheduling and reminder calls;
- calls relating to payments;
- purely market research or customer satisfaction calls;
- calls relating to your inquiry, order or request; and
- solicited calls.
- Opting out of direct marketing, electronic communications and telemarketing
If you do not wish to receive direct marketing advertising, electronic communications or telephone calls for direct marketing purposes from us, you may opt out at any time. We will stop sending material to you when you opt out, unless you change your preferences.
To opt out please call us on 1800 448 326 or send us an e-mail at email@example.com. When you opt out, you can choose to opt out of particular direct marketing, or all direct marketing.
If you decide not to receive any direct marketing material from us, you may miss out on promotions, invitations to certain events, publications, special products or services or other items that may be classified as direct marketing.
- Credit related information
IVECO may from time to time,itself or through its finance arm CNH Industrial Capital Australia Pty Limited, use your personal information to assess your credit situation when you apply for some products. For example, we generally do a credit assessment before you take a finance product. It will entail asking you for information about yourself and things like your employment details and credit history.
We will as a matter of best practice seek a credit report from a credit reporting agency. We’ll always tell you before we seek a credit report. The credit report provided by a credit reporting agency may include information like your employment history, previous credit checks, any problems you’ve had paying bills and whether those issues were resolved. We will use this information to assess whether we’re entering into an arrangement that is financially viable for both you and us.
After you become a customer, we will store the crucial bits of information from the credit report and our own credit assessment. We may continue to use this information to manage credit, and to make sure we’re offering and providing the right services to you. We will occasionally use credit related information to generate marketing lists in order to offer you new products or services. Sometimes, we might ask a credit reporting agency to do that for us. You can ask the credit reporting agency not to use your information for these purposes by getting in touch with them directly.
IVECO works with its overseas related entities and third-party suppliers which will have access to the credit information they need to help manage credit and your services. The overseas entities conduct operational, technology and customer service functions on our behalf:
If the personal information held has an error, CNH Industrial will correct it. If CNH Industrial has previously disclosed that information to a credit reporting agency we’ll tell them about the error and ensure the information is corrected. You can ask the credit reporting agencies not to use or disclose the information in their files if you think you have been or are likely to become a victim of fraud.
We will not:
- report credit related information about individuals under the age of 18 (in Australia); and
- report defaults of less than $150 (in Australia) or $125 (in New Zealand).
Before reporting defaults to credit reporting bodies, we will give you a notice in writing stating that we intend to disclose the information to the credit reporting body within 14 days (if in Australia). We will give you notice that payment is overdue and will not report the defaults unless you are at least 30 days overdue (if in New Zealand). If you believe that you have been or are likely to be the victim of fraud (including identify fraud), you can request a credit reporting body not to use or disclose the information they hold about you. If you do this, the credit reporting body mustn't use or disclose the information during an initial 21 day period (if in Australia) or an initial 10 day period (if in New Zealand) without your consent (unless the use or disclosure is required by law). In Australia, this is known as a ban period.
In Australia, if, after the initial 21 day ban period, the credit reporting body believes on reasonable grounds that you continue to be or are likely to be the victim of fraud, the credit reporting body must extend the ban period as they think reasonable in the circumstances. The credit reporting body must give you a written notice of the extension. In New Zealand, you may ask the credit reporter to extend the suppression beyond the initial 10 day period if you think the fraud is continuing.
Credit reporting bodies can use the personal information about you that they collect for a pre- screening assessment at the request of a credit provider unless you ask them not to. A pre-screening assessment is an assessment of individuals to see if they satisfy particular eligibility requirements of a credit provider to receive direct marketing. You have the right to contact a credit reporting body to say that you don't want your information used in pre-screening assessments. If you do this, the credit reporting body must not use your information for that purpose.
You can find out more about the credit reporting agencies we engage by visiting www.equifax.com.au (If you are an Australian Customer) and www.equifax.co.nz (if you are a New Zealand customer) and their websites give their contact details and their policies about the management of your personal information.
3. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
If you ask us, we will usually give you access to the personal information we hold about you. IVECO will always confirm your identity before giving access to your personal information. You can ask for access or correction of your personal information by contacting us by any of the methods below, though we may request that a correction be put in writing for our records:
Phone: 1 800 448 326
The APPs and NZIPPs prohibit us from giving you access to personal information we hold about you if:
- it would unreasonably affect someone else’s privacy; or
- giving you access poses a serious threat to someone’s life, health or safety.
There is generally no cost for accessing the personal information we hold about you, unless the request is complex or resource intensive. If there is a charge, it will be reasonable and we will let you know what it is going to be so that you can agree to it before we go ahead.
- Quality of personal information
IVECO is committed to ensuring all the personal information we hold about you is accurate, up-to-date, complete, relevant and not misleading having regard to the purpose for which it is held. If you think our records need to be corrected, please call us on Phone: 1 800 448 326 firstname.lastname@example.org. IVECO encourages you to update your details with us so we can deliver better service to you.
If we do not agree that your information is inaccurate, incomplete or out of date, we will write to you and tell you the reason(s) why we do not agree with you. We will also tell you what you can do if you are not satisfied with our response.
4. HOW YOU CAN COMPLAIN IF YOU THINK WE HAVE BREACHED THE APPS AND NZIPPS AND HOW YOUR COMPLAINT WILL BE HANDLED
You are entitled to complain if you believe that your privacy has been compromised or that IVECO has breached the Privacy Act, or an applicable code. Please contact us and we will try our best to resolve the matter.
For security reasons, we may request proof of your identity and that your complaint, request for access or correction of your personal information or any other privacy matter to be put into writing, and either e-mailed or posted to:
The Privacy Officer
IVECO Trucks Australia Ltd, 1 Princes Highway, Dandenong South, Victoria, 3175
If you make a written complaint, IVECO will respond within a reasonable time (usually less than 30 days). When this is not possible, IVECO will contact you within that time to let you know how long we will take to resolve your complaint. IVECO will investigate your complaint and where necessary, consult with other credit providers or credit reporting bodies about your complaint. Once we have made a decision about your complaint we will write to you to explain our decision.
For additional information about privacy or if your concerns are not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au and on 1300 363 992 (if you are an Australian customer) or the Office of the Privacy Commissioner (OPC) at www.privacy.org.nz and on 0800 803 909 (if you are a NZ customer) about the handling of your personal information.
5. DISCLOSURE OF PERSONAL INFORMATION TO OVERSEAS RECIPIENTS
Your personal information may be disclosed during the ordinary course of our day to day business and those of our related and associated entities and service providers (e.g. cloud service providers, servers).
IVECO will only give secure access to the personal information to the extent they need to do their job. IVECO maintains effective control of your personal information at all times including by taking reasonable steps to ensure that parties located overseas comply with the APPs and NZIPPs in relation to your personal information unless an exception applies in the relevant Privacy Act.
6. RETAINING DATA