Privacy AND CREDIT REPORTING Policy
We respect the privacy of individuals and take protecting Personal Information seriously. We are bound by the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
This privacy and credit reporting policy applies to the privacy practices in Australia of Goodyear & Dunlop Tyres (Aust) Pty Ltd (Goodyear & Dunlop Tyres) and its Related Bodies Corporate. This policy explains how we manage Personal Information, including Credit-related Information, to ensure we meet our obligations under the Privacy Act. Part A applies to Personal Information and Credit-related Information generally and Part B provides specific detail about how we handle Credit-related Information.
In addition to this privacy and credit reporting policy, we will on occasion provide specific statements to you about how we use particular information that we collect.
In this policy, the expressions we, us and our are a reference to Goodyear & Dunlop Tyres and its Related Bodies Corporate. The expressions you and your refer to each individual whose Personal Information we may handle from time to time where we are required to comply with the Privacy Act in respect of such Personal Information, including the individuals described in Part B in relation to any Credit-related Information.
Credit-related Information means any “credit information” or “credit eligibility information” as defined under the Privacy Act. References to “Personal Information” in this privacy and credit reporting policy include Credit-related Information. Examples of the Credit-related Information that we may collect are set out under the heading “The kinds of Personal Information that we collect and hold”.
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.
Related Bodies Corporate has the same meaning as under the Corporations Act 2001 (Cth).
Sensitive Information has the same meaning as under the Privacy Act.
Spam Act means the Spam Act 2003 (Cth).
PART A – PRIVACY
The kinds of Personal Information that we collect and hold
We only collect Personal Information to the extent that this is reasonably necessary for one or more of our functions or activities. The types of Personal Information that we collect and hold about you will depend on your interaction with us. Generally, we will collect and hold your name, contact details and information relating to your dealings with us.
But we may also collect additional Personal Information about you in certain circumstances, for example if you:
- are a customer of Goodyear & Dunlop Tyres or a Goodyear & Dunlop Tyres franchisee;
- use our website;
- apply to us to become a franchisee of Goodyear & Dunlop Tyres;
- apply to Goodyear & Dunlop Tyres for credit (or a company of which you are a director applies for credit, or you propose to guarantee credit applied for by another person); or
- apply to work with Goodyear & Dunlop Tyres.
We also collect Credit-related Information about you in certain circumstances, or derive Credit-related Information about you (including from credit reports provided by a credit reporting body). The types of Credit-related Information about you that we collect or derive includes:
- information contained in credit reports obtained from credit reporting bodies, which includes information about consumer and commercial credit history with other credit providers;
- identification information, including current and prior names and addresses, any known alias, date of birth, gender, current or last known employer and driver’s licence number;
- your bank account details;
- your financial information;
- court proceedings information, which includes information about a judgment against you that relates to any credit that has been provided to, or applied for, by you;
- personal insolvency information;
- certain publicly available information about you;
- scores, ratings, summaries, evaluations and other information relating to your credit worthiness which is derived by us or by credit reporting bodies wholly or partly from any of the information above.
How we collect Personal Information
Our preference is to collect Personal Information about an individual directly from that individual unless it is unreasonable or impracticable for us to do so.
Goodyear & Dunlop Tyres collects Personal Information about you in a number of different ways.
We may collect Personal Information directly from you or in the course of our dealings with you, such as when you provide Personal Information to us, you order our products or services, you use our website or apply for a job with us, you complete our forms or otherwise during the course of our relationship with you or a company of which you are a director, you have provided a guarantee for credit terms or where otherwise permitted under the Privacy Act. If we have extended a credit facility to you, we will also collect information internally about your payment performance.
We may also collect Personal Information about you from publicly available sources, or in some cases, from third parties including:
- Goodyear & Dunlop Tyres franchisees;
- consumer credit reporting bodies and businesses;
- other sources that provide commercial credit reports, information or searches about commercial trading activities, credit worthiness or company details;
- recruitment agencies and your referee;
- market research firms;
- other organisations who have provided commercial credit to you; and
- any other person or organisation that you ask us to collect your Personal Information or Credit-related Information from.
You may have the option, if it is lawful or practical, to remain anonymous or use a name other than your own (a pseudonym) when you deal with us. For example, when you make a general enquiry about our products or services.
If you choose to deal with us anonymously or the Personal Information you provide to us is incomplete or inaccurate, we may not be able to provide our services to you effectively. For instance, if we are not able to collect Personal Information about you, we may not be able to:
- provide you with product recall information;
- provide you with products or services and information or assistance; or
- tailor the content of our websites to better meet your requirements,
to the extent that these activities require us to collect, use or disclose Personal Information.
Purpose of collection of Personal Information
We may collect, hold, use and disclose Personal Information as reasonably necessary for our functions or activities and as permitted by law. The purposes for which we collect your Personal Information include, but are not limited to:
- verifying your identity;
- contacting you (including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner);
- providing you with our products or services;
- assessing and progressing (if appropriate) your job application;
- developing and improving our goods and services, maintaining and developing our systems and infrastructure and obtaining feedback; and
- for marketing and promotional purposes.
The purposes for which we collect your Credit-related Information include, but are not limited to:
- assessing whether to provide you, or company of which you are a director, or have provided a guarantee for credit terms, with credit or to accept you as a guarantor for credit applied for by another person;
- deriving scores, ratings, summaries and evaluations relating to your credit worthiness (which are used in our decision-making processes and ongoing reviews);
- managing credit we provide;
- enabling us to participate in the credit reporting system and provide information to credit reporting bodies as permitted by the Privacy Act;
- assigning debts;
- collecting overdue payments;
- undertaking debt recovery and enforcement activities, including in relation to guarantors;
- dealing with complaints and meeting legal and regulatory requirements; and
- assisting other credit providers.
Some Personal Information (including Credit-related Information) may only be used or disclosed under Australian privacy laws for some of these purposes or in some circumstances.
Use and disclosure of Personal Information
We may use or disclose your Personal Information for the primary purpose of collection, for a secondary purpose that is related (or directly related, for Sensitive Information) to a purpose for which we collected it, where you would reasonably expect us to disclose your Personal Information for that secondary purpose, or where you provide us your consent or we are otherwise required or authorised to do so by law.
The purposes for which we may use or disclose your Personal Information include, but are not limited to:
- carrying out our business functions and activities, including meeting our legal and regulatory obligations;
- responding (including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner) to your enquiry, feedback or complaint and providing you with any products and services you may have requested;
- administering, assessing, processing and reviewing your credit or guarantee application, credit account and credit worthiness and managing your credit with us (or the credit of an entity of which you are a director or guarantor);
- administering, investigating, reporting and resolving any claims, complaints or incidents;
- assessing and processing your employment application, including conducting reference checks;
- improving the service we provide and also to let you know about promotions, discounts, upcoming events or products or services that may be of interest to you;
- preventing fraud; or
- engaging in debt recovery activities; and
- any other purposes disclosed at or around the time we collect the Personal Information (including any Credit-related Information).
We may also disclose your Personal Information to others, where permitted under the Privacy Act, including to:
- our Related Bodies Corporate;
- third party service providers that provide financial, legal, administrative or other services required in connection with the operation of our business;
- third parties, including government agencies, where required or allowed by law and the courts; and
- any third party with your consent.
Communications from us
We do not use Sensitive Information for marketing purposes. Your Personal Information (excluding Sensitive Information) may be used and disclosed for marketing and promotional purposes where you have provided your consent to us doing so.
We may contact you by mail, email, SMS or fax to provide you with information about our products or services or other services and products we think may be of interest to you. If you have provided us with your preferred method of communication we will endeavour to use that method wherever practical to do so. If you wish to cease receiving marketing information from us, you may notify us using the contact details provided below or by using any opt-out facilities provided in the marketing communications. Please note that even if you have requested not to receive further direct marketing communications, we may nevertheless continue to provide you with information about changes to our terms and conditions for the supply of goods or services and other factual information as permitted under the Privacy Act and Spam Act.
Overseas disclosures of Personal Information
Goodyear & Dunlop Tyres is part of the Goodyear Australia corporate group, and a subsidiary of The Goodyear Tire & Rubber Co., Inc., which is a global organisation based in the USA. We, including our Related Bodies Corporate and subcontractors, may hold electronic records of your Personal Information using cloud technology or by other electronic means. These means of holding Personal Information may include offshore storage.
In the course of our ordinary business operations we may disclose Personal Information to those Related Bodies Corporate and subcontractors. In particular, we commonly disclose Personal Information to our Related Body Corporate located in the Philippines. We will take reasonable steps to ensure that our Related Body Corporate in the Philippines handles your Personal Information in accordance with the Australian Privacy Principles. The third parties to whom we disclose your Personal Information overseas may change. As such, while we take reasonable steps to ensure this list is accurate, it is not practicable for us to specify in advance the location of every service provider with whom we deal.
In accordance with the Privacy Act, this policy does not apply to our acts and practices directly related to a current or former employment relationship between us and an employee, and an employee record held by us relating to the employee.
If we transfer employee records offshore for any reason, we will make reasonable endeavours to ensure that your Personal Information is handled in accordance with the Privacy Act.
Storage and security of Personal Information
We, or our related entities or service providers on our behalf, may hold Personal Information (including Credit-related Information) about you in computer systems, electronic form, digital records, telephone recordings or in paper files.
The security of your Personal Information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. We will also destroy or de-identify Personal Information once we no longer need it for any purpose for which the information may be used, disclosed or retained under the Privacy Act.
When using our website you should be aware that no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect such information, we do not warrant the security of any information that you transmit to us over the Internet and you do so at your own risk.
A cookie is a small file which is sent to your browser and stored on your computer and helps us understand and track your use of our website and where we can improve your user experience and the information and services we provide to you.
We may work with third parties to research certain usage and activities on our website. No Personal Information about you is shared except to the extent it is required to be used by a third party or parties for providing such research, and in the course of conducting this research we, and these third parties may place a unique “cookie” on your browser.
Access, correction and requests for further information
We will take such steps as are reasonable to ensure that the Personal Information (including Credit-related Information) which we collect remains accurate, up to date and complete.
We will provide you with access to your Personal Information (including Credit-related Information) held by us unless we are permitted under the Privacy Act to refuse to provide you with such access. Please contact us using the contact details below if you:
(a) wish to have access to the Personal Information which we hold about you;
(b) consider that the Personal Information which we hold about you is not accurate, complete or up to date;
(c) would like to make a request that a credit reporting body not use credit reporting information for the purposes of pre-screening direct marketing by a credit provider, or you think you have been a victim of fraud; or
(d) require further information on our Personal Information handling practices.
In some cases we may be able to deal with your request over the phone or at a store. We may charge you a small fee to cover our costs when giving you access to Personal Information we hold about you, but we’ll always check with you first. No charge will be made for simply making the request and we will not charge you for making a request to update or correct your Personal Information.
If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps, consistent with our obligations under the Privacy Act, to correct that information if you so request.
We will respond to all requests for access and/or correction within a reasonable time.
If you have any questions or concerns about our collection, use or disclosure of Personal Information (including Credit-related Information) or if you believe that we have not complied with this privacy and credit reporting policy or the Privacy Act, please contact our Privacy Officer using the contact information below and provide details of your question or concern so that we can investigate it. Your question or complaint must be made in writing, so we can be sure about the details of the complaint.
When contacting us, please provide as much detail as possible in relation to the query, issue or complaint. We will use reasonable efforts to deal promptly with complaints and inquiries and acknowledge your complaint or inquiry within a reasonable time.
Any complaint will be taken seriously and will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with relevant information we may require.
If you are not satisfied with our response or how we handled your complaint, you may complain to the Office of the Australian Information Commissioner (in writing) at:
Office of the Australian Information Commissioner (OAIC)
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Please direct contact regarding privacy queries, issues or complaints to the following areas:
Attention: Privacy Officer
Goodyear & Dunlop Tyres (Aust) Pty Ltd
PO Box 8086
MELBOURNE VIC 3000
Phone: +61 3 8416 7200
Changes to our privacy and credit reporting policy
PART B – credit reporting Notification
Part B of this privacy and credit reporting policy applies to current and former credit customers of Goodyear and Dunlop Tyres and its Related Bodies Corporate in Australia, as well as to other relevant individuals we deal with in connection with credit we provide (such as guarantors and directors).
This Part B notification should be read in conjunction with Part A of this privacy and credit reporting policy.
When does this credit reporting policy apply?
If an individual, or company of which an individual is a director, applies to us for a Commercial Credit Account (credit terms) in connection with the supply of goods under our Trading Terms and Conditions of Trade (or an individual applies to us to provide a guarantee for credit terms) we may obtain a consumer credit report or commercial credit report about the individual from a credit reporting body when the Privacy Act permits us to do so.
We may also obtain a consumer credit report or commercial credit report about an individual from a credit reporting body when the Privacy Act permits us to do so, if an individual, or company of which an individual is director, has been provided with credit terms, or has provided a guarantee for credit terms.
When we request a credit report from a credit reporting body, we will provide information to the credit reporting body that identifies the individual, and we may give information about the credit terms, including the type and amount of credit.
Disclosure to Credit Reporting Bodies
Where the Privacy Act permits us to, we may disclose your personal information (including credit information) to credit reporting bodies.
We currently disclose personal information to:
PO Box 964
North Sydney NSW 2059
Phone: 13 8332
CreditorWatch Pty Ltd
GPO Box 4029 Sydney NSW 2001
Phone: 1800 738 524
You can obtain a copy of Equifax’s and CreditorWatch’s policies about their management of Credit-related Information. To do so, please contact them or visit their website at www.experian.com.au or www.creditorwatch.com.au
Credit reporting bodies may include the information provided by us in credit reports provided to other credit providers to assist them to assess your credit worthiness. The credit we provide is commercial credit. However, you should remember that if you fail to meet your payment obligations in relation to consumer credit provided by other credit providers, or if you commit a serious credit infringement in connection with consumer credit, the relevant credit provider may be entitled to disclose that information to credit reporting bodies.
We currently disclose Personal Information (including Credit-related Information) to our Related Body Corporate located in the Philippines who provides services to us. Please see the heading “Overseas disclosures of Personal Information” in Part A for further details of our overseas disclosure of Personal Information.
Your rights in relation to Credit-related Information
You have the right to:
(a) request us to give you access to the Credit-related Information we hold about you;
(b) request us to make a correction to the Credit-related Information we hold about you; and
(c) make a complaint to us if you are concerned that we have not complied with our obligations that apply to dealing with Credit-related Information under the Privacy Act.
Please see the heading “Access, correction and requests for further information” in Part A for further details about how to contact us to exercise these rights.
Opting out of direct marketing pre-screening
A credit reporting body may use your credit reporting information to assist a credit provider to market to you by pre-screening you for direct marketing by the credit provider. This process is known as a “pre-screening”. If you do not want a credit reporting body to use your information for the purpose of pre-screening, you have the right under the Privacy Act to contact them and request that they exclude you from pre-screening (at no cost to you).
If you are a victim of fraud (including identity fraud)
You are entitled under the Privacy Act to request that a credit reporting body not use or disclose credit reporting information they hold about you in circumstances where you reasonably believe that you have been, or are likely to be, a victim of fraud, including identity fraud. The period while this applies is called a “ban period”. The credit reporting body will explain to you in more detail the effect and duration of a ban period when you contact them.
If you have any questions about this notification or require a hard copy, please contact us using the details under the heading “Contact us” in Part A.
Last Updated: September 2019