Ingham Privacy Statement

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Effective Date 1st January 2023

1. ABOUT THIS STATEMENT

Ingham has this privacy statement because we understand that it is important for you to know how we collect, store, use and share your personal information. By “Ingham” we mean all it’s associated companies and brand partners of Ingham Group Services Limited.

In this statement we refer to Ingham as “we”, “us”, “our” or “Group”.

By entering any of our dealerships, service centres, using our websites, mobile sites, apps, platforms, dealership Wi-Fi or services, participating in our database, promotions, or any membership programme, or interacting with our Customer Engagement Centre, you acknowledge that your personal information will be treated as described in this statement.

By placing an order to purchase products from a third party seller via our websites, apps and platforms, you understand that personal information that is necessary to fulfil your order will be disclosed to the third party seller, and that the terms of the third party seller’s Privacy Policy will also apply.

PERSONAL INFORMATION

In this statement, “personal information” means the same as it does in the Privacy Act 2020 (“Privacy Act”). In general terms, this includes any information that can be used to personally identify you. This may include (but is not limited to) your name, age, gender, address, contact details (including phone numbers and email addresses), images of you, your biometric data and financial information, including your payment information. If the information we collect personally identifies you, or you are reasonably identifiable from it (for example, if we combine seemingly anonymous data with other personal information, we hold about you), then the information is considered personal information.

CHANGES TO THE PRIVACY STATEMENT
We may change this privacy statement from time to time. Updated versions of this statement will be posted on our website. If we make any significant changes, we will provide you with reasonable notice by informing you through the Inghamdriven websites, apps and/or via email. By continuing to engage with us or use our services after any such notice period, you will be deemed to have accepted the updated version of this statement.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect personal information from you when you:

Purchase products or services from us in dealership.

We collect:

Video footage or still images, where our dealerships operate video surveillance system (wherever you see video surveillance systems and/or a sign notifying you “CCTV IN OPERATION” or similar, including in-store and in our carparks).
The number plate of the vehicle you have used to visit our dealership, if that dealership uses an Automatic Number Plate Recognition (ANPR) system.
Details of the products and services that you have purchased from us or have shown interest in.
Payment information and tokenised card data, in order to facilitate the payment for the goods and/or services.
Where you have or intend to purchase goods and or services which need to be obtained at a later date (for example, from another store location), or you have purchased an additional warranty or support, we may collect your name, email address, contact number and mailing or street address).
If you access our dealership WiFi, we collect your name, email address, marketing opt-in preference, device identifier, device operating system, and your web browser settings.

Purchase products or services from us online

We collect:

Details of the products and services that you have purchased from us.
Details of the products that you have not purchased, but have shown an interest in.
Information necessary to deliver those products and services, to respond to your enquiries including your name, email address, contact number, mailing or street address, delivery instructions and recipient details. In the case of in-home services, we may also collect information about your availability and details necessary to provide the service (for example, products being delivered).
Details of your store preference, for the purpose of fulfilling your click and collect order
Payment information and tokenised card data, in order to facilitate the payment for the goods and/or services.

Access, browse, and engage with our websites, apps, and communication platforms
We collect:

The content that you access including products, services and information that you searched for and browsed for.
Whether you have opened, read or engaged with emails or other communications that we have sent you.
The internet protocol (IP) address used to connect your computer or device to the internet, your login information, data on your screen settings and device settings, such as the point and scroll settings of your mouse, web browser type and version, time zone settings, and operating system information.
We also collect information about your use or visit, including statistical information about visits to pages on the site, page response times, duration of individual page view, page interaction information (such as scrolling, clicks and mouse-overs) and the paths taken by you to, through and from our websites, apps and communication platforms (including date and time).
Where you submit an enquiry, test drive request or register your interest for a product, we collect your name, email address and any information that you provide, including any message you provide us.

Interact with us through live chat on our websites

We collect:

Your name and email address, along with the contents of your message.

Interact with us through any of our programmes, or those of our third-party partners

We collect:

Information about your participation (for example, whether you have opened, read or engaged with emails or other communications that we have sent you, or redeemed offers served to you).
Your third-party membership identifier (e.g. insurance customer number).

Engage with our dealership staff in person

We collect:

Your name and contact information (for example, your email address and/or contact phone number).
Information regarding why you have engaged with our staff (for example, information relating to a vehicle enquiry or a service).
Information you provide to us through customer surveys.

Contact our dealership staff via phone or email
We collect:

Your name, contact phone number and the subject matter of your call (which may be recorded).
Your email address and any contact information provided, along with the contents of your email.
Information you provide to us through customer surveys.

Complete an application for a product or service
We collect:

Your name, email address, contact number(s) and physical address.
In certain circumstances (for example where you apply for credit or insurance related services), we may also collect your age or birth date, your profession, occupation, proof of identity (such as a driver’s licence number), and credit history, reports and financial information).

Enter promotions that we run or facilitate
We collect:

Your name, email address, contact number(s) and mailing and/or street address.
Any information that you provide as part of the entry requirements (for example, the receipt or online order number and entry question responses).

Interact with us on social media
We collect:

Your social media handle, along with any information that you provide to us.

Collection from publicly available sources and third parties
You acknowledge and authorise us to also collect personal information about you from publicly available sources and third parties, including:

Third-party companies such as credit reporting agencies, other retailers (for the purpose of preventing criminal behaviour), law enforcement agencies, and other government entities
Advertisers including social media platforms (for example, Facebook)
Mailing lists
Contractors and business partners
Suppliers or manufacturers
Other businesses within the Ingham Group.

In some cases, we may purchase second-party data from any of the categories of third parties listed above. Where we do so, we seek appropriate warranties from those third parties that they have the necessary consents and authorisation to sell and disclose any personal information contained in those datasets to us for our own business purposes. Any personal information we collect from third parties for the purposes identified in this statement may be combined with other information we hold about you.

Ingham accesses the Motor Vehicle Register (MVR) to access ownership details in compliance with the Land transport Act 1998 by Waka Kotahi, specifically section 241 (www.gazette.govt.nz/notice/id/2022-au4073).

IF WE ARE NOT ABLE TO COLLECT PERSONAL INFORMATION

If you choose not to provide us with the personal information described within this statement, then:

We may not be able to provide you with the product or services you have requested, either to the same standard or at all
We may not be able to provide you with information about products or services that you may want, including information about discounts, sales or special promotions
We may not be able to tailor our content, website and communications for your preferences.

3. COOKIES

A “cookie” is a small text file that is placed on a device when it is browsing a website to enable the host of the website to store information about use of the website by that device. We use cookies and similar technologies (for example, pixels) to:

Recognise your computer or device and greet you each time you visit our websites, without bothering you with a request to register or log-in.
Keep track of products or services you view, so that we can send you, directly or through third parties, information and advertisements about those products or services or other similar or related products or services from across the Group that we think you may be interested in.
Measure traffic patterns, to determine which areas of our websites have been visited, and to measure transaction patterns in the aggregate.
Research our users’ habits so that we can improve our products and services.
Operate our websites efficiently with a high level of functionality.
Measure the effectiveness of our marketing initiatives.
Learn about your preferences so that we can present you with web content and advertising that is relevant to you.
Measure the number of advertising referrals we have received to our websites from other websites.
Produce data on web traffic and customer web activity through our website or apps.

While we use cookies to improve our customers’ online experience, if you do not wish to allow cookies then you can choose to disable cookies (for all sites) from within your browser settings. Please note that disabling cookies could affect your online experience.

4. WHY DO WE COLLECT PERSONAL INFORMATION?

The primary purpose for which we collect information about you is to enable us to perform our business activities and to provide the best possible customer service.

We collect, hold, and use your personal information to:

Provide products and services to you.
Provide you with information or advice about existing and new products and services.
Manage product or service warranties or guarantees, including product or safety recalls.
Communicate with you and process your requests, including to interact with you via social media.
Manage and enhance our products and services.
Provide you with, operate and manage our membership programmes and those of our third-party partners.
Personalise and customise your experience with us and the other businesses within The Inhgam Group and to tailor how we market our products and services to you based on your purchase history and purchase preferences.
Provide you with access to secure areas of our websites and apps.
Provide you with notices regarding updates to your customer experience.
Conduct competitions or promotions, either ourselves or on behalf of selected third parties.
Verify your identity and/or enable you to create and use a payment identity (e.g. through the use of digital wallets).
Provide to third parties if you have authorised us to do so.
Conduct analysis and generate insights across our Group businesses.
Conduct business processing functions for the operation of our websites or our business, for our administrative, marketing, promotional, planning, product/service development, quality control and research purposes, or those of our contractors or external service providers.
Create aggregated and anonymised datasets of customer derived information for commercial purposes.
Investigate if we have reason to suspect a breach of any of our terms and conditions or any suspected unlawful activity.
Help prevent fraud and unlawful activity.
Link previous actions that you have taken on our websites or in our dealerships with historic data that we have collected but have not been able to identify as yours. For example, tokenised payment card data and device identification data.
Undertake activities otherwise required or permitted by any law (including the Privacy Act).

Your personal information will be held at the appropriate Ingham dealership. It may also be held for us in the data centres, platforms and systems of our third-party service providers, some of which may be located outside of New Zealand.
Your personal information will not be shared, sold, rented or disclosed other than as described within this statement or as required or permitted by any law (including the Privacy Act).

5. USE OF PERSONAL INFORMATION FOR MARKETING

We use personal information to provide you with information or advice about our existing and new products and services. We may combine and analyse a range of personal information we hold about you for the purpose of providing a more personalised shopping/viewing experience and/or providing more targeted advertising based on your preferences.
We also use and disclose personal information to conduct promotions on our own behalf and on behalf of selected third parties (for example if you enter a joint promotion that we are running with a third-party, we may share your personal information with that third-party for the purposes of facilitating the promotion).

If at any stage, you no longer wish to receive these marketing communications you may unsubscribe by using the link in any promotional email, logging into your account and changing your preferences or contacting us at customer.care@inghamdriven.nz.

Please note that if you unsubscribe from any of our marketing databases, you may still receive important product and service-related communications from us. You may also still receive marketing material from other brands within The Ingham Group or our third-party business partners if you have agreed or requested to receive information from those parties. If you do not wish to receive marketing communications from these other organisations, you must let them know directly.

We will not collect usage data or target advertisements based on the following market categories:

Political opinions
Membership of a political association
Religious beliefs or affiliations
Philosophical beliefs
Membership of a trade union
Sexual preferences or practice
Criminal record
Health information

If you receive communications from us that you believe have been sent to you other than in accordance with this statement, or in breach of any law, please contact us at crm@inghamdriven.nz.

6. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

The Ingham Group

We may share your personal information across businesses within The Ingham Group:

For the operation of our websites and our business
For the purposes of providing, operating and managing our programmes
For the specific purpose of fulfilling requests by you
To provide products and services to you
To undertake customer analytics and insights to better understand our joint customer base, to tailor marketing material and campaigns, to undertake and perform remarketing across our retail brands and paid media platforms, and to develop aggregated and anonymised customer datasets to supply and/or sell to third parties
Where we are permitted to under the Privacy Act
As otherwise detailed in this statement

Service Providers, Suppliers and Associated Third Parties
Where we engage third parties to undertake services for us or on our behalf, we may provide those third parties with some of your personal information if it is required to fulfil those services and only to the extent required to fulfil those services. Examples of such third-party providers may include, but is not limited to:

Service providers such as web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, photographic analysers, data entry service providers, electronic network administrators, debt collectors, and professional advisers such as accountants, solicitors, business advisors and consultants
Software providers such as customer relationship management and accounting software
Suppliers, business partners or joint venture entities or partners who we engage or partner with to perform certain services or functions on our behalf
Sponsors, or promoters of any competition that you have entered into that we conduct or promote
Specific third parties authorised by you to receive information held by us

We may also disclose your personal information to manufacturers or suppliers of products or services for product warranty or guarantee fulfilment purposes, to facilitate repair of a product or where the manufacturer or supplier has advised that they need to contact you for any issues related to the quality or safety of the product or service you have purchased.

Where we transfer personal information outside of The Ingham Group, we contractually require third parties to take reasonable steps to protect your information against unauthorised use or disclosure in accordance with the requirements of the Privacy Act.

Disclosures
In addition to the above, we may disclose personal information:

to third sellers to enable them to fulfil orders that you have made via our platforms;
to other local retailers, where we reasonably believe that it is necessary in order to protect our staff, customers or property or to assist other businesses to do the same;
when it is permitted under the Privacy Act or required by law for legal compliance and law enforcement (including to government agencies with statutory law enforcement responsibilities, and/or to your Internet Service Provider or network administrator);
to facilitate court proceedings;
enforce or apply our terms and conditions;
to protect our or your rights, property, or safety and the rights, property and safety of our users, or others, and where we reasonably believe that disclosure is necessary;
to Government agencies with statutory roles enabling them to request data from us include the Police, Inland Revenue and the Ministry of Business, Innovation and Employment.

7. DISCLOSURE OF PERSONAL INFORMATION OUTSIDE OF NEW ZEALAND

If we disclose personal information to a third party outside of New Zealand for any of the purposes listed above, and that third party uses the personal information for their own purposes, we will ensure that the third party is subject to privacy laws that are comparable to the Privacy Act or is otherwise required to protect the personal information in a way that provides comparable safeguards to those in the Privacy Act.

8. PROTECTION AND RETENTION OF PERSONAL INFORMATION

We take reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorised access or modification.

Where our dealerships operate CCTV systems, they ensure that access to CCTV footage is limited to staff who have a legitimate purpose to view and use it.

We retain your personal information only for as long as we need it and we destroy the information we no longer need in a secure manner. CCTV footage is automatically deleted on a regular cycle, though in some cases it may be retained for longer where necessary to investigate an incident or assist the Police to investigate an offence.

If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.

9. RIGHT TO ACCESS OR CORRECT YOUR PERSONAL INFORMATION

You may request access to any personal information we hold about you at any time by contacting us at crm@inghamdriven.nz.

Your request will be processed in accordance with the Privacy Act.

If you make an access request, we will ask you to verify your identity. There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it breaches legal professional privilege. If that happens, in most circumstances we will give you written reasons for any refusal.

We may charge a reasonable fee for making your personal information available to you or providing you with copies of it.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may ask us to amend it. We will consider if the information requires amendment and will not charge for making any amendments. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it. Registered users of our websites and apps can access and update their user details online. We request that you keep your information as current as possible so that we have the most accurate and up to date information available to us.

10. COMPLAINTS ABOUT A BREACH OF PRIVACY

If you believe that we have breached this statement or the Privacy Act or you have any questions or concerns about this statement, please contact us using the contact information below and provide details of the incident so that we can investigate it.

We have a formal procedure for investigating and dealing with complaints. Once the Privacy Officer receives a complaint the Privacy Officer will commence an investigation with the relevant business unit. The investigator will endeavour to determine the nature of any breach and how it occurred.

We may contact you during the process to seek further clarification if necessary. If a breach is found, the Privacy Officer will escalate the matter to management so that the process can be rectified to help prevent any further breaches from taking place. We will also contact you to inform you of the outcome of the investigation. We will endeavour to resolve all investigations within a reasonable timeframe.

We will treat your requests or complaints confidentially.

You can contact our Privacy Officer by email at crm@inghamdriven.nz or by post at: Privacy Officer, Ingham Group Services Limited, 2 Great South Road, Newmarket, Auckland 1050. PO Box 99855, Newmarket, Auckland 1149.

If you consider your query or privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, you can contact the New Zealand Office of the Privacy Commissioner via their website www.privacy.org.nz or free phone at 0800 803 909. Further information about how to lodge a complaint is available on the Privacy Commissioner’s website.