This policy applies to Inchcape Automotive Retail Pty Limited ACN 000 806 904 trading as Subaru Narellan ('Subaru Narellan') and outlines our obligations in managing personal information we hold about customers, potential customers, contractors and others who come into contact with us and our related companies. We want your experience with Subaru Narellan in both our online and offline environments to be enjoyable and we take care to respect your privacy.

Subaru Narellan are bound by the National Privacy Principles ('NPPs') contained in the Privacy Act 1988 (Cth) ('Privacy Act') that require us to handle your personal information responsibly. 'Personal Information' is defined within the Privacy Act as information or an opinion about an individual which can be used to identify that individual.

The primary purposes for which Subaru Narellan collects your personal information include:

• to provide and market our products and services;
• to inform you of our special offers and events and to facilitate and process your acceptance order of any special offers, products and services;
• to create a better, more personalised experience with Subaru Narellan for you; and
• to help us manage and enhance our products and services.

Generally, we use the information we collect about you for the primary purpose for which it is collected and for reasonably expected secondary purposes. We limit the collection of sensitive information about customers (e.g. ethnic origin, political opinions, etc.) because, in general, it is not necessary for what we do.

Subaru Narellan also takes reasonable steps to provide clear, complete and up-to-date information about our business and the products and services we offer. This includes how to get in touch with us. This information helps you to make informed choices.

If you have a concern with the collection or use of your personal information you can notify Subaru Narellan of your concern, make a complaint, obtain redress or pursue dispute resolution by simply contacting the Privacy Officer using the details set out below.

In general, the type of personal information Subaru Narellan collects and holds includes but is not limited to; names, addresses, contact details, occupations and other information that will assist us in providing our products and services.

When we collect your personal information we endeavour to:

• tell you whom we are and what we intend to do with your information when we receive it. We strive to be open - upon request we will let you know what sort of personal information we hold about you, how we collect it and how we use and disclose it. Subject to the Privacy Act you may request access to the personal information we hold about you by contacting the Privacy Officer via the details set out below (Note: We will require you to verify your identity and to specify the information that you require. A fee may be charged for providing access. We will advise the likely cost in advance.)
• take steps to ensure that your personal details are accurate, complete and up-to-date when we use or collect them. You have the right under the Privacy Act to request changes to your personal information. We encourage you to contact us in order to update any personal information we hold about you using the Privacy Officer contact details set out below.
• collect personal information only by lawful and fair means generally by forms filled out by you (whether on-line or in hard copy), face-to-face meetings, interviews, business cards and third parties (e.g. companies we contract to collect data on our behalf). From time to time, we may also collect non-personal information e.g., information specific to a vehicle or model. This helps us in our ongoing efforts to improve our products and services.

We may also monitor your usage of our web site to make improvements and provide other items you might want to know about. We may also use third parties to analyse traffic on our website, which may involve the use of cookies. Information collected through such analysis is anonymous.

As much as reasonably possible, we will collect your information directly from you, although we may from time to time also use external sources that are legally entitled to disclose and use your personal information.

We may disclose your personal information to:

• our related companies;
• the manufacturers of vehicles that we sell;
• insurance companies;
• credit providers;
• other companies or individuals who assist us in providing services or who perform functions on our behalf (such as mailing houses) who are generally contract bound to protect your privacy;
• law enforcement bodies such as the Police, who seek access to your personal information for law enforcement purposes; and
• anyone else to whom you have authorised us to disclose it.

We may also collect your personal information from these companies and individuals, in which case we will deal with this information in accordance with this Policy.

Unless otherwise required or permitted by law, if we disclose your personal information to others we will only do so with your consent (implied or express), and we will also take steps to ensure the party to whom we have disclosed your information agrees to protect the privacy of your personal information.

The Spam Act 2003 (Cth) prohibits the sending of commercial electronic communications without the consent of the person to whom the communication is being sent. In line with Subaru Narellan's commitment to technology (but within the parameters of the law) Subaru Narellan would like to accommodate customers who wish to be contacted by way of electronic communications. These communications may be sent for any of the purposes mentioned above. Subaru Narellan may at the point of collection of personal information request the mobile phone number or the email address of our customers. Where customers provide these details Subaru Narellan will request the consent of an individual to use these details for electronic communications such as SMS and email. Whenever such messages are sent to a customer Subaru Narellan will always provide the customer with the option of opting out of receiving similar communications by way of electronic means in the future.

The Do Not Call Register Act 2006 prohibits the making of telemarketing calls (as defined in the legislation) to numbers listed on the Do Not Call Register. In line with Subaru Narellan's commitment to corporate compliance, Subaru Narellan will only contact numbers that appear on the Do Not Call Register in the limited circumstances allowed by the Do Not Call Register Act 2006 and the Telecommunications (Do Not Call Register) (Telemarketing and Research Calls) Standard 2007, such as where you have given us the requisite consent to do so. Where you give us express consent to contact you by telephone we will deem it to be supplied for an indefinite period for the purposes of the Do Not Call Register Act 2006, unless otherwise advised or withdrawn by you.

We always provide individuals with an opportunity to "opt-out" of receiving future communications from Subaru Narellan. If you have received a communication from us and don't wish to receive new information from us in the future, just use the "contact us" form on our website or write to or email the Privacy Officer on the details set out below and we will take appropriate steps to ensure your details are marked as "private" on our internal database and/or added to our 'Do Not Mail' list to ensure you will not receive any future communication from us. Subaru Narellan does not send marketing communications to customers who have asked us to mark their details as private or who have opted out of receiving such information.

Please note that in some cases your details may be retained in the event that we may need to contact you in relation to such matters as vehicle safety, recalls, warranty and any requirements specified by law.

We take all reasonable steps to protect the security of personal information collected by us. We understand that customers require peace of mind when it comes to the security of providing their personal information to Subaru Narellan. We have internal methods to ensure that your personal information is safe and protected against misuse, loss or unauthorised access, modification or disclosure. Where we no longer require your personal information for a permitted purpose under the NPPs, we will take reasonable steps to destroy or suppress your personal information.

Subaru Narellan may disclose your personal information to its related companies, including those located outside Australia. Subaru Narellan takes steps to ensure that such recipients respect the confidentiality of this information by abiding by the NPPs or equivalent privacy laws.

Other than as stated above, we will not send your personal information to recipients outside of Australia without:

• obtaining your consent (in some cases this consent will be implied); or
• otherwise complying with the NPPs.

Due to an exemption in the Privacy Act this policy does not apply to Subaru Narellan's treatment of an employee record, where that treatment is directly related to the current or former employment relationship between Subaru Narellan and the individual.

This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. We will at all times make available any information regarding our Privacy Policy to anyone who requests it, whether at our offices, or by our website.

We welcome your questions and comments about our handling of your personal details and this Privacy Policy.

Please let us know by using the 'contact us' form on our website. You may also contact our Privacy Officer at:

Privacy Officer

Email:	privacy.officer@subarunarellan.com.au
Facsimile:	(02) 9828 9120
Postal address:	Privacy Officer Subaru Narellan Level 2 4 Burbank Place Baulkham Hills NSW 2153