XtraVIRAL recognises the importance of protecting an individual’s privacy. We appreciate that individuals are concerned about the security of their personal information and we are committed to protecting any personal information we hold. Personal information is information or an opinion about an individual who is reasonably identifiable.

In accordance with the 13 Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Privacy Act), this Privacy Policy details how XtraVIRAL will manage and protect personal information, including information that XtraVIRAL collects and uses for the purpose of providing better customer service by striving to meet our customers’ needs and expectations about our cars and other products.

This Privacy Policy generally does not apply in relation to current or former XtraVIRAL employees.

XtraVIRAL dealers are independent of XtraVIRAL and have privacy policies which differ from ours. XtraVIRAL dealers are responsible for their own privacy policies and privacy practices. Please contact your XtraVIRAL dealer directly for further information. XtraVIRAL may amend this Privacy Statement at any time. The updated version will be available by following the”Privacy Policy” link on XtraVIRAL’s website homepage, at www.XtraVIRAL.com . XtraVIRALmay highlight changes to this Privacy Policy on its homepage, but you shouldcheck the Privacy Policy regularly for changes.

Collecting personal information

XtraVIRAL will be fair and open about the way we collect information about you and what we intend to do with the information.

XtraVIRAL may collect and hold personal information about you such as your name, address, telephone number,   date of birth and any other information you may voluntarily provide to us.

XtraVIRAL collects most personal information directly from you, forexample when you provide information through market surveys, product focusgroups,  the websites operated by XtraVIRAL,our customer assistance service, email communications and telephone enquiries.Third parties and related companies may also share information with us. We mayalso collect your personal information if you enter a competition or promotionwe run (either directly or through our marketing agents), or through a recruitmentor employment agency.

Using personal information

XtraVIRAL only collects, holds and handles information about you that is necessary for us to perform the services you request from us, that is otherwise reasonably necessary for our business activities or if required by an Australian law or court or tribunal order.

We may use personal information we collect about you for a number of purposes including:

  • to tell you about other products and services that may be of interest to you;
  • to learn more about your level of satisfaction, your expectations of us and how we can meet them;
  • to run a competition or promotion you have entered;
  • to consider you for a position at XtraVIRAL for which you have applied;
  • to acquire goods or services from you or from your employer;
  • for other purposes to which you have consented; and
  • as required or permitted by relevant laws and regulations.

Generally, we may use your personal information for the purposes for which we collected it and for related purposes which would be reasonably expected by you. If you do not provide your personal information, XtraVIRAL is less able to perform the above functions.

Disclosing personal information

XtraVIRAL may need to disclose personal information outside of the jurisdiction from which it was collected. When we disclose your personal information overseas, XtraVIRAL is generally required to take reasonable measures to ensure that your information is held, managed and accessed in accordance with the standards that apply in Australia. In relation to health information about an individual, we will generally only disclose the information outside of the state or territory where we collected it if we reasonably believe that the recipient of the information is subject to a law,binding scheme or contract which upholds principles for fair handling of the information that are substantially similar to the principles that apply in the state or territory of collection.

We may disclose personal information we collect about you for different purposes including:

  • to assist our related companies and other service providers (such as information technology service providers so that they can provide the services that we have contracted out to them;
  • to provide information to our Dealers so that they can provide goods or services to you or respond to a complaint by you, or to help them improve the quality and standard of service they provide to you;
  • to your nominated referees so that we may check your references if you are applying for a position with XtraVIRAL; and
  • as required by relevant laws and regulations.

XtraVIRAL may disclose personal information to such entities located outside Australia. We will not sell, rent or trade your information to/with any other organisation.

Consent

We may require your consent to use and/or disclose your personal information if we need to use your information for a purpose that is not related to the purpose for which it was collected. If you do not consent to XtraVIRAL collecting, using and/or disclosing your personal information, this may affect XtraVIRAL’s ability to deliver and improve its products and services.

Marketing and privacy

XtraVIRAL sends marketing materials to its customers and other people who have provided XtraVIRAL with personal information from time to time about products and services offered by XtraVIRAL, its Dealers and its affiliates. If you do not wish to receive marketing materials from XtraVIRAL or its affiliates, please complete the opt-out provision on the marketing information sent to you and return it to XtraVIRAL. XtraVIRAL will note your request and respect your wish not to receive any marketing materials.

Cookies

We use cookies and track IP addresses via our websites so we can improve our services provided by our websites and enhance your user experience.

Cookies are pieces of information a website can send to your computer’sbrowser for record-keeping purposes. We use cookies to ascertain which webpages are visited and how often, to make our websites more user friendly, togive you a better experience when you return to a website and to targetadvertising to you that we think you may be interested in. For example, cookiesallow us to save your password so you do not have to re-enter it every time youvisit our site. Most web browsers automatically accept cookies. Cookies can bedisabled or purged from your browser if you so choose. You can find informationspecific to your browser under the “help” menu. We can’t guarantee the proper functioning of our websites if you choose to disable cookies.

Protecting personal information

XtraVIRAL will keep your personal information secure by taking reasonable steps to protect it from misuse, loss and unauthorised access,modification and disclosure. XtraVIRAL stores personal information in transmission logs and archive systems for a period XtraVIRAL considers reasonable depending on the primary purpose for which that information was collected. Only properly authorised people who have a need to access personal information to perform their job will be able to see or use that information. The physical and electronic security systems at XtraVIRAL comply with the guidelines of the Information Commissioner.

Personal information will be de-identified or destroyed when it is no longer required such that it cannot be re-identified at a later date. The de-identification and destruction process will be in accordance with the guidelines of the Information Commissioner.

XtraVIRAL will ensure that its employees receive training (and refresher training) about the management of personal information relevant to the irrespective roles and responsibilities.

XtraVIRAL will take reasonable steps to keep any personal information we hold about you secure. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict,exclude or modify any statutory rights under any applicable law including the Privacy Act or the Competition and Consumer Act 2010 (Cth). Please notify us immediately if you become aware of any breach of security.

Accessing and requesting correction of personal information

We will strive to ensure that information about you is accurate when we collect or use it. Subject to some exceptions under the privacy legislation, we will let you see the information we hold about you and correct it if it is inaccurate, incomplete or out-of-date. If we do not grant you access to your personal information we will tell you why.

If you wish to obtain access to and/or correct your personal information held by XtraVIRAL, please contact XtraVIRAL. XtraVIRAL will provide written acknowledgement of receiving your request for access within 7 days of receipt. Unless it does not agree to your request for access to personal information, in most cases XtraVIRAL will provide you with access within 30 days of receipt of your request. If you request corrections to your personal information and XtraVIRAL agrees with your request, these changes will be made as soon as practicable. If XtraVIRAL does not agree to your request for correction, it will notify you of the reasons it does not agree and will note your request on the records it holds about you. If you remain dissatisfied you may also complain to the Information Commissioner (at http://www.oaic.gov.au).

Resolving your concerns

If you have a complaint regarding XtraVIRAL’s management of your personal information, please prepare your complaint in writing and email XtraVIRAL. XtraVIRAL will provide written acknowledgement of your complaint within 7 days of receipt. We will investigate and advise you of the steps we have taken to resolve your complaint within 30 days of receipt of your complaint.

Privacy and XtraVIRAL employees

Due to the “employee records exemption” in the Privacy Act, XtraVIRALis generally not required to comply with the Privacy Act in relation to personal information held in its employment records concerning current or former XtraVIRAL employees. Therefore, this Privacy Policy generally does not apply in relation to current or former XtraVIRAL employees. However, XtraVIRAL recognises that employee records should nevertheless be handled carefully, and XtraVIRAL will comply with any obligations that may apply to employee personal information under other applicable laws.

XtraVIRAL may disclose personal information held in its employment records for different purposes including: to our related companies (such as General Motors and XtraVIRAL New Zealand) and to service providers (such as information technology service providers, payroll service providers,recruitment service providers, third parties that provide services in relation to XtraVIRAL’s internal feedback and reporting programs and service providers who assist XtraVIRAL with “on-boarding” new staff) so that they can provide the services that XtraVIRAL has contracted to them to perform.

XtraVIRAL employees may seek to access, update or correct the personalinformation which XtraVIRAL holds about them by contacting their HumanResources Manager. Such requests will be assessed on a case by case basis.

The employee records exemption does not apply (and this Privacy Policy does apply) to:

  • independent contractors;
  • secondees into XtraVIRAL who remain employees of the seconding client or firm;
  • voluntary work experience students; or
  • job applicants.

Health records legislation also applies to health information about employees collected or handled in Victoria and this Privacy Policy will apply to that information.

Further questions

If you have any questions about this Privacy Policy or our privacy practices, please contact us.

Date of this Privacy Policy: June2014