We comply with the Privacy Act 1988 (Cth) (Privacy Act) and its Australian Privacy Principles (APPs), which set out standards for the collection, use, disclosure and handling of Personal Information.

In this Privacy Policy "we", "our" and "us" means Wheels Finance Pty Limited ACN 169 131 944 (Wheels Finance), its authorised representatives and related companies.

This Privacy Policy applies to any personal information we collect, handle, use or disclose.

What is Personal Information?

The kinds of Personal Information we collect and hold vary depending on the services we are providing. Not all Personal Information we collect will be collected for every individual.

In this Privacy Notice, references to “personal information” also include:

Sensitive information which includes information or an opinion about an individual’s racial or ethnic origin, membership of a political, professional or trade association and health information);

Credit information which includes your identification details, information about your credit facilities and whether these are open or closed and the relevant dates, the type of credit or loans, the amount of credit, repayment history information and details of defaults or court proceedings or insolvency; and

Credit eligibility information which includes information about you disclosed to us by a credit provider that has a bearing on your credit worthiness or eligibility for consumer credit.

See the Privacy Act for full details.

Customer Information includes Personal Information as follows:

• contact information such as full name (first and last), e-mail address, current postal address, delivery address (if different to postal address) and phone numbers;
• driver's licence;
• details relating to employment (if applicable) or previous employment;
• date of birth and gender;
• financial situation including income and credit history (if applicable);
• insurance history (if applicable);
• information relevant to vehicle ownership, registration, loan repayments, maintenance insurance and claim logs (if applicable); and
• any relevant payment or billing information, (including but not limited to bank account details, direct debit, credit card details, billing address, premium funding and instalment information).

How do we collect and hold Personal Information?

We only collect Personal Information by lawful and fair means and where it is reasonably necessary for, or directly related to, one or more of our functions or activities.

We collect Personal Information in the following ways:

Wheels Finance website - any consumer-directed website operated by Wheels Finance; and

We hold the Personal Information we collect within our own data storage devices or with a third party provider of data storage. We discuss the security of your Personal Information below.

For what purposes do we collect, hold, use and disclose Personal Information?

We collect, hold, use and disclose your Personal Information where it is reasonably necessary for, or directly related to, one or more of our functions or activities, to offer and administer our various products and services or otherwise as permitted by law. We do not use or disclose Personal Information for any purpose that is unrelated to our services and that you would not reasonably expect (except with your consent).

The Wheels Finance service and its purposes are described on our website at www.wheelsfinance.com.au. These purposes include:

General purposes

More generally, our purposes include responding to enquiries; providing assistance; maintaining and administering our products and services; providing quality assurance and training; performing administrative operations (including accounting and risk management); and any other purpose identified at the time of collecting your information.

Third party disclosure

We usually disclose Personal Information to third parties who assist us or are involved in the provision of our services and Personal Information is disclosed to them only in connection with the services we provide or with your consent. The third parties include our related companies and our representatives who provide services for us, our agents or contractors, our legal, accounting and other professional advisers, data warehouses and consultants and our alliance and other business partners and any other parties where permitted or required by law.

These parties are prohibited from using your Personal Information except for the specific purpose for which we supply it to them and we take such steps as are reasonable to ensure that they are aware of the provisions of this Privacy Policy in relation to your Personal Information.

If we give third parties (including their agents, employees and contractors) your Personal Information, we require them to only use it for the purposes we agreed to.

If we do propose to disclose or use your Personal Information other than for the purposes listed above, we will first seek your consent prior to such disclosure or use.

What happens if you don't give us your Personal Information?

If you choose not to provide us with the information we have requested, we may not be able to provide you with our services or products or properly manage and administer services and products provided to you or others.

What are your rights to anonymity and pseudonymity?

You have the option of not identifying yourself or using a pseudonym provided we are not required or authorised by or under an Australian law, or a court/tribunal order to deal with individuals who have identified themselves or it is not impracticable for us to deal with you on this basis.

It will generally be impracticable for you to deal with us anonymously or using a pseudonym if you wish to use our services or have us arrange a product for you.

What do we expect of third parties we deal with in relation to Personal Information?

When you provide us with Personal Information about other individuals, we rely on you to have made them aware that you will or may provide their information to us, the purposes we use it for, the types of third parties we disclose it to and how they can access it (as described in this document). If you have not done this, you must tell us before you provide the relevant information.

If we give you Personal Information, you and your representatives must only use it for the purposes we agreed to.

Where relevant, you must meet the requirements of the APPs set out in the Privacy Act, when collecting, using, disclosing and handling Personal Information on our behalf.

You must also ensure that your agents, employees and contractors meet the above requirements.

How do we protect the security of your Personal Information?

We endeavour to protect any Personal Information that we hold from misuse, interference and loss, unauthorised access, modification and disclosure.

We maintain physical security over our paper and electronic data stores and premises, such as locks and security systems. We also maintain computer and network security; for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to computer systems where Personal Information is stored.

We also use third party facilities for storage. We require at least the same level of security to be provided by those third party facilities.

Do we transfer information overseas?

We do not disclose information to persons located overseas.

What are your rights in relation to the accuracy of and access to your Personal Information?

We will take reasonable steps to ensure that the Personal Information we hold about you is accurate, complete and up to date, whenever it is collected, used or disclosed.

The accuracy of Personal Information depends largely on the information you provide to us, so we rely on you to:

• let us know if there are any errors in your Personal Information you become aware of; and
• keep us up-to-date with changes to your Personal Information (such as your name or address).

You are entitled to access your Personal Information if you wish and request correction if required except in some exceptional circumstances provided by law. For example, we may refuse access where the:

• information may have an unreasonable impact on the privacy of others;
• request is frivolous or vexatious;
• request is frivolous or vexatious;information relates to existing or anticipated legal proceedings and would not be accessible by the process of discovery in those proceedings;
• information would reveal our intentions in relation to negotiations in such a way as to prejudice those negotiations.

Where providing access would reveal evaluative information generated by us in connection with a commercially sensitive decision-making process, we will provide an explanation for the decision rather than direct access to the information.

If we refuse access or to give access in the manner requested by you we will let you know why in writing and provide you with details about how to make a complaint about the refusal.

If we make a correction to your Personal Information we may retain a copy of the previous information for our records or as required by law.

If you wish to access your Personal Information please contact us.

In most cases we do not charge for receiving a request for access to Personal Information or for complying with a correction request.

Our Website

You are able to visit our website without providing any Personal Information. We will only collect Personal Information through our websites with your prior knowledge for example where you submit an enquiry or application online.

Email addresses are only collected if you send us a message and will not be automatically added to a mailing list.

Cookies

A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use may identify individual users.

• Cookies can either be "persistent" or "session" based. Persistent cookies are stored on your computer, contain an expiration date, and are mainly for the user's convenience.
• Session cookies are short-lived and are held on your browser's memory only for the duration of your session; they are used only during a browsing session, and expire when you quit your browser.
• We may use both session and persistent cookies. This information may be used to personalise your current visit to our websites or assist with analytical information on site visits.
• Most internet browsers can be set to accept or reject cookies. If you do not want to accept cookies, you can adjust your internet browser to reject cookies or to notify you when they are being used. However, rejecting cookies may limit the functionality of our website.

What happens if you have a complaint?

If you believe:

• your privacy may have been prejudiced; or
• we or our representatives have breached the APPs or an APPs code,

then you have the right to make a complaint about the matter.

In the first instance, your complaint should be addressed in writing to us (see the How to contact us section for contact details). We will investigate the matters raised by you and respond directly to you.

If you are dissatisfied with our response, or you have not received a response from us of any kind to your complaint within 30 days, you should refer the matter to the Office of the Australian Information Commissioner (OAIC) in accordance with the Act. OAIC can be contacted on 1300 363 992 or at www.oaic.gov.au.

This Privacy Policy is current from April 2015. In the event that this Privacy Policy or any part thereof is amended or modified in the future, the revised version will be available at our office or on our website.

How to contact us

If you wish to gain access to your Personal Information, want us to correct or update it, have a complaint about a breach of your privacy, wish to withdraw your consent to any of the uses of your information including receiving offers of products or services from us, or have any other query relating to our Privacy Policy, please contact us.

Wheels Finance Pty Limited

Baulkham Hills BC NSW 2153

Level 2, 216-14 Lexington Drive

Bella Vista NSW 2153

Phone: +61 2 9877 0300

Fax: +61 2 9877 0277

Email: info@agi.net.au

Website: www.wheelsfinance.com.au

You can also obtain information on privacy issues in Australia on the Office of the Australian Information Commissioner ("OAIC") website at www.oaic.gov.au or by contacting the OAIC by email at enquiries@oaic.gov.au or by calling on 1300 363 992.