Purpose

This Privacy Policy applies to Servco Australia Solutions Pty Ltd ACN 641 578 989 and Servco Australia Essendon Fields Pty Ltd ACN 648 199 759 (Blinkr).

Blinkr is committed to complying with the Privacy Act 1988 (Cth) including the Australian Privacy Principles.

This Privacy Policy is intended to provide a clear and concise summary of Blinkr’s approach to the handling of personal information in accordance with the Australian Privacy Principles.

Our Privacy Policy appears on our website and we will also provide a copy of our current Privacy Policy to anyone who makes a request, free of charge.

Consent

By using our website at https://www.blinkr.com.au/ or providing your personal information to us, you will be deemed to have consented to Blinkr handling your data in accordance with this Privacy Policy.

What is personal information?

Under the Privacy Act 1988 (Cth) personal information is defined to mean 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.

Personal information can include sensitive information. Sensitive information is defined as information or an opinion about a person’s race, ethnic origin, political opinions, membership of political associations and trade associations, religious or philosophical beliefs, sexual orientation or practices, criminal record, health information, genetic information about an individual that is not otherwise health information, biometric information that is used for the purpose of automated biometric verification or biometric identification and biometric templates.

Personal information that we collect and hold

Blinkr collects, holds and uses personal information during the course of your dealings with us (for example when you purchase products or services from us or when we purchase goods from you). If we do not collect personal information, or the information provided is incomplete or inaccurate, we may not be able to buy or sell products or provide our services, or our services may be compromised.

We generally collect personal information in the following ways:

• information that you give to us (for example through our website, via social media channels, via email, video call or via telephone)
• information that we get from your use of our website
• information that you provide to us in person (for example when you submit and enquiry with us, complete a transaction with us, take a vehicle for a test drive, or use one of our loan vehicles)
• information we receive from third party service providers, for example our payment gateway service provider, one of our finance providers or third party service providers we use to verify a match between vehicles and owners
• publicly available sources
• using cookies and similar technologies via our website

The types of personal information that we can collect and hold include:

• your name
• your contact details including address, email address and telephone number
• order and quotation information including details of all products purchased or sold such as service history of vehicles
• for vehicle purchases, we also collect information such as the vehicle make, model and colour, options and accessories supplied, price paid, trade-in details, vehicle identification number, registration details, driver’s licence number, odometer reading, finance and insurance details and details of any roadside assistance services or extended warranty purchased
• payment details to take deposits or complete payment which may include details of credit card, debit card or any other method of payment
• where we act as agent of a credit provider we may also collect your date of birth, driver’s licence details or other details required to verify your identity, financial information and credit liability information about you and information about the credit application which you are making
• information that you provide when you register or create an account with us
• records of any competitions or promotions you enter
• information from third party services to enable Blinkr to monitor and analyse web-traffic and can be used to keep track of website user behaviour

We may also collect other personal and sensitive information from you (for example, if you are applying for employment then we may collect your resume, qualifications, skills, education provider and history, work history and residency status). We may also collect any details contained within identity documents provided to us, including but not limited to government identifiers (for example, a passport number, driver’s licence number, Medicare card number, etc.). We do not generally collect (or, if it is provided by you to us, retain) any sensitive information about you.

Google Analytics

We use Google Analytics to collect information about the use of our website. Google Analytics collects information about your visit to our website but does not collect your personal information.

Some of the information that Google Analytics collects includes:

• server and IP address
• domain name
• type of browser used
• date and time of visit
• pages accessed and documents downloaded
• the previous website that you visited
• if you have visited our website before

Although Google Analytics adds a permanent cookie on your web browser to identify you as a unique user the next time you visit this website, the cookie cannot be used by anyone except Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognising you on return visits to this site by disabling cookies on your browser.

Google Analytics is a tool to measure website traffic and usage. You can opt out of the collection of this information using a tool like the Google Analytics Opt-out Browser Add-on.
Cookies

We may use cookies. A cookie is a small text file which may be placed on your Internet browser and which we access each time you visit a website. Without limitation, we may use cookies to:

• help the website to function correctly or to improve the usability, content or user experience of the website
• monitor our website’s performance
• for security
• build up a picture of the websites, products and services you prefer, so that we can then provide you with a personalised experience of our website and provide you with information of interest to you
• place advertisements for our products on other external sites
• monitor how our marketing is performing

Most browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies. You may delete or decline cookies by changing your browser settings. (Click “Help” in the toolbar of most browsers for instructions or review the cookie management guide produced by the Interactive Advertising Bureau – www.allaboutcookies.org.) If you do so, some of the features and services of the site may not function properly.

Disclosure of your personal information

Blinkr never sells any personal information.

Blinkr may disclose your personal information to:

• our related entities
• personnel involved with the operation of this website including IT, administration, sales, marketing and system administration staff
• lawyers and other professional advisers
• finance, insurance, extended warranty and roadside assistance providers (where you have requested that they supply products and services to you)
• our service providers and contractors including providers of outsourced vehicle repair and maintenance services, mail carriers, couriers, hosting providers, IT companies and communications agencies
• valuers (to assess the value of your vehicle) and vehicle registries (to check whether a trade in vehicle is encumbered)
• Government authorities (for example for vehicle registration and compulsory third party (bodily injury) insurance or as required under financial transactions reporting or anti-money laundering legislation)
• Police, local council authorities or our insurers if a test drive or loan vehicle is involved in any parking or traffic infringements or is damaged whilst in your possession
• financial institutions for payment processing
• referees, referrals or guarantors whose details you have provided to us
• our agents, associates and business partners
• any entity to which we are required or authorised by or under law to disclose such information
• to prospective or actual buyers in the event we sell our business or assets

Use of your personal information

Blinkr uses personal information for the purpose of buying and selling its products and associated services including facilitation of payment and delivery.

Personal information is also used for the following purposes and services:

• responding to your enquiries and contacting you or communicating with you
• managing support and contact requests
• internal record keeping, management and administration
• to meet contractual obligations
• administering warranties
• to understand more about you, so that we can provide better products and services
• verifying information that you provide to us
• website heat mapping and session recording
• analytics
• hosting and back end infrastructure
• displaying content from external platforms
• remarketing and behavioural targeting
• marketing and advertising
• interaction with external social networks and platforms
• content commenting and moderation
• where you are applying for finance, to assist your financier to assess and process your finance application
• where applicable, to assist insurance, extended warranty and roadside assistance providers to assess your request or provide their products or services to you

Marketing and advertising

Blinkr will never use or disclose any sensitive information for marketing or advertising purposes.

We may use and disclose your personal information (other than sensitive information) to provide you with information about products or services offered by Blinkr or other companies or entities. You consent to receipt of direct marketing information including by email or SMS.

If at any time you do not wish to receive marketing communications from us or you do not want your personal information disclosed for marketing purposes, please contact our Privacy Officer and we will remove your details from our marketing database.

Data Integrity

Blinkr endeavours to ensure that all personal information that it holds is accurate, complete and up-to-date. To assist us with this, individuals should contact us if any of their personal information changes, or if they believe that the personal information we have is not accurate or complete.

When personal information that we collect is no longer required by Blinkr, we will destroy or de-identify that personal information unless we are required by law or a court/tribunal to retain the personal information.

We may retain personal information for so long as it is required for any of our business purposes, for the prevention of fraud, for insurance and governance purposes and in our IT back-up.

Security

We may hold your personal information in electronic formats or in hard copy. Generally, we aim to store your personal information securely to ensure that your personal information is not protected from unauthorised access, modification and disclosure, and from other types of misuse, interference and loss.

While we will take reasonable steps to protect the personal information that we hold from misuse, loss, unauthorised access, modification or disclosure, you should be aware that no system is completely secure against cyber attack.

In addition, the open nature of the internet is such that information exchanged via the internet may be accessed and used by people other than those for whom the data is intended. Any information sent via the internet is sent at the sender’s risk.

You should contact us immediately if you believe that there has been unauthorised access or disclosure with respect to any personal information that we hold about you.

Information about third parties

If you provide us with personal information about a third party, in doing so you will be representing to us that you have that person’s consent for us to collect and handle their personal information in accordance with this policy – and we will be collecting the information on that basis.

Disclosure Overseas

Blinkr is unlikely to disclose your personal information overseas to persons other than technical service providers, hosting providers, IT companies and manufacturers, however if we do so, it will be in accordance with the Australian Privacy Principles.

Our payment system is based in Australia.

Our servers are located in Australia and the United States of America.

You consent to any disclosure of your personal information by Blinkr overseas on the understanding that if the overseas recipient handles the personal information in breach of the Australian Privacy Principles, the entity will not be accountable under the Privacy Act 1988 (Cth), and you will not be able to seek redress under the Privacy Act 1988 (Cth). The overseas recipient may not be subject to privacy obligations or to any principles similar to the Australian Privacy Principles. Individuals may not be able to seek redress in some overseas jurisdictions, and overseas recipients may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.

De-identified data

You consent to Blinkr using and disclosing your de-identified data (data that no longer identifies you) for any purpose, including without limitation research, statistical analysis, product development, marketing and business planning and any other commercial purpose. We undertake technical measures to make sure that this data cannot be associated back to you.

Government related identifiers

Blinkr may collect government-related identifiers for the purposes set out in this policy, but Blinkr does not use any government-related identifiers, such as driver’s licence or passport numbers, as its own internal identifier of any individual. Blinkr will not use or disclose any government-related identifiers other than in accordance with the Privacy Act 1988 (Cth).

Access and correction

Individuals can request access to their personal information held by Blinkr by sending a written request to our Privacy Officer.

Blinkr does not impose a charge for making a request for access, however we may charge for reasonable administrative costs incurred in providing access.

You can ask our Privacy Officer to request or update your personal information. Blinkr does not impose any charge with respect to requests for correction or updates.

Before providing access to personal information, or correcting or updating personal information, Blinkr will require your identity to be confirmed.

Requests for access or correction may be refused upon the grounds contained in the Privacy Act 1988 (Cth). If we refuse to provide access, or to correct or update personal information, Blinkr will provide you with reasons for the refusal. If we refuse to correct your personal information you have the right to associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. We will take such steps as are reasonable in the circumstances to associate that statement with all records we hold that contain the relevant information.

Notifiable data breaches

We will notify you and the Office of the Australian Information Commissioner about any data breach that is likely to result in serious harm to you. There are exceptions where notification is not required, for example where we have already taken appropriate remedial action that removes the risk of serious harm to any individuals.

Complaints

Privacy related complaints should be directed to our Privacy Officer in writing at the address below.

We will do our best to ensure that our investigation is completed, and a decision about your complaint is communicated to you, within 30 days of our being advised of the complaint. We will inform you if we need more time.

If you are dissatisfied with Blinkr’ response, you can take your complaint to the Office of the Australian Information Commissioner. For more information see https://www.oaic.gov.au/privacy/privacy-complaints/.

Blinkr’ Privacy Officer

Blinkr’s Privacy Officer’s contact details are:

Email: privacy@blinkr.com.au

Address: Blinkr Privacy Officer
PO Box 5257

West End
QLD 4101
Australia

Effect of this Privacy Policy

This Privacy Policy does not create any rights or obligations that you can legally enforce beyond the rights and obligations provided by the Australian Privacy Principles.

Changes to this Privacy Policy

This policy may be amended from time to time. We will publish any updated versions of this policy on our website at https://www.blinkr.com.au By continuing to use our website, order any product or use any Blinkr service, you will be deemed to have consented to any amended versions of this policy that are published on our website.

Last updated 8 July 2022