1. Introduction
Penrose Motors Ltd (also referred to as “our” or “us” or "we") is committed to protecting the privacy of personal information of our current, former and potential customers (also referred to as “customers” or “you” or “your”) and to complying with our obligations to you under the Privacy Act 2020 (“Act”).
This privacy policy describes how we will manage your personal information held by us, including how we collect, use, hold, disclose and otherwise process that information. You will also find information about how to contact us if you have any queries, including how to update or access your personal information or make a complaint.
By providing us with your personal information (whether directly or indirectly) you accept and consent to the provisions of this privacy policy. If you have any questions or concerns regarding this privacy policy, please contact us.
It is important to note that, if we are unable to collect, use, hold, disclose and otherwise process your personal information in the manner authorised by this privacy policy then we may not be able to provide you with the services we provide.
2. The types of personal information we collect.
Below we have described some examples of the types of personal information that may be collected, however this may not be an exhaustive list:
- Your name and contact details, including physical and postal address, email addresses, phone numbers, mobile numbers, and driver’s license if you loan a car.
- Financial and credit information if you apply for finance via one of our 3rd party providers.
- Information about your vehicle, including its number plate, vehicle identification number (VIN), NZTA data, and service history where available.
- If you request or receive roadside assistance services, we may collect information about where (e.g. location) and when (e.g. date, time) you requested roadside assistance services and the assistance service that is required.
- Recordings of you from our Closed-Circuit Television (CCTV) security system.
- Information about your use of or interest in the services that we provide, for example enquiry details, your feedback or opinion on products and services, and records of your communications with us.
- Information that you share as part of your public profile on a third-party social network, or information you create and share with us by posting it to one of our social networks.
- Information relating to the way you use or navigate any of our websites, customer portals and mobile applications so that we can improve your experience and our communications with you online.
- Other personal information that we are permitted or otherwise required by law to obtain, as well as any other information that you choose to provide us.
3. The ways in which your personal information is collected.
We collect personal information from or about you in a variety of ways. Where possible we will collect personal information directly from you. We may also collect information from persons you have authorised to share your personal information with us, or from whom you authorise us to collect personal information. The most common ways we collect personal information are:
- from you directly either in person, over the phone, by email, or through our digital and online channels, for example. when:
- you make an enquiry about services, parts, or accessories:
- if you interact with us online, including via our websites or through our social media channels;
- if you enter a promotion or competition carried out by us or by a third party with official affiliation or support from us;
- from the Motor Vehicle Register, in accordance with our authorisation to access this register for specified purposes under section 241 of the Land Transport Act 1998;
- from any third-party provider of motor vehicle finance;
- from other third parties, including our business associates, service providers, contractors, and agents.
4. Why we collect personal information and what we do with it
We, and the Permitted Recipients referred to in paragraph 5, may collect, hold, use and disclose and otherwise process your personal information for the following purposes (and for any related purposes which you would reasonably expect):
- to enable us to correspond with you and do business together and for reasons related to our business operations, such as to ensure we continue to deliver quality services to our customers and potential customers;
- to administer or assist in administering your ongoing vehicle service, and enabling us to obtain required parts on a timely basis to meet your needs;
- to facilitate your application for finance for the service of your vehicle;
- to facilitate your application to open a trade account with us;
- to lodge or assist in an insurance claim;
- if you have a credit history with us, to provide trade references on your behalf;
- to respond to your enquiries, comments, concerns or requests for information about parts, accessories, services;
- to process sales orders and administer accounts, and vehicle service records;
- for product development, market research, and customer surveys (for example, to obtain your feedback and find out your level of satisfaction with our services);
- for marketing and promotional activities, including to contact you directly or through authorised service providers;
- to compile aggregate data and generate reports and data about our service usage patterns;
- to carry out our legal compliance obligations;
- to send you service and Warrant of Fitness reminders;
- to contact you with details new services offered by us or by other parties, or special offers or promotions, that we think may be of interest to you;
- we may use information collected from our websites to enable the features of the websites, to improve the websites by determining which of our products, features and services are most popular, and to personalise the experience of the users of our websites;
- for other purposes which are disclosed to you, and to which you consent, whether expressly or by implication by providing us with your personal information with knowledge of how we intend to use it; and
- without your consent for purposes that are required or authorised by or under any applicable law.
5. Who has access to your personal information?
We respect the privacy of your personal information and will take all reasonable steps to keep it strictly confidential. However, we may disclose your personal information to third parties if required in connection with one or more of the purposes set out in paragraph 4 of this privacy policy. This may include disclosure to the following persons (in each case, a “Permitted Recipient”):
- our employees, officers, contractors, suppliers, service providers; (for example, marketing agencies, financiers, website and data hosting providers, online messaging providers, data analytics providers, and other IT suppliers);
- our affiliated or related entities and their respective employees, officers, contractors, suppliers, service providers, agents, partners, and licensees;
- our accountants, insurers, lawyers, and other professional advisors;
- if your vehicle is provided by your employer as part of a corporate or government fleet policy, we may also disclose personal information to your employer;
- any other third parties to whom you direct or permit us (whether expressly or by implication) to disclose your personal information (e.g. third parties with whom we have directly or indirectly arranged services for your benefit);
- third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
- as otherwise permitted or required by or under any applicable law.
In each case, the disclosure of personal information to a Permitted Recipient may be made directly by us to a Permitted Recipient or by a Permitted Recipient to another Permitted Recipient (for example, Manufacturers may disclose personal information directly to their suppliers).
A Permitted Recipient of your personal information shall only be entitled to use your personal information as required for the purposes for which it was provided to them, which shall be consistent with the purposes described in this privacy policy.
6. Disclosure of personal information outside of New Zealand
Some of the Permitted Recipients to whom we disclose personal information may be located outside New Zealand. Our websites and systems may be based on servers located outside of New Zealand. Please note that the privacy laws of countries outside of New Zealand may not be as comprehensive as the laws of New Zealand. In addition, if a Permitted Recipient is in a jurisdiction outside of New Zealand, the information held by that Permitted Recipient may be subject to that jurisdiction, including access requests from government, courts or law enforcement in that jurisdiction.
If we disclose personal information to third parties based offshore, we will comply with the requirements of the Act that relate to the transfer of personal information offshore.
7. Use of Cookies
Our websites use back-end techniques known as cookies to record the preferences of visitors and enable websites to be optimised. A "cookie" is a data element that a website transfers to your computer for record keeping and experience customisation. User’s computers store cookies for a time determined by the user’s browser settings.
"Cookies" are IT industry standard and help to monitor the effectiveness of advertising and how people use our websites. With usual website usage website "cookies" do not store your email address or other personal information about you unless you have given your consent, or if it is essential for technical reasons (i.e. secure login). The technology is used to generate statistics and measure website activity to improve the efficiency of customer visits and help with ad campaigns. We may also use analytics data supplied by third party vendors to inform and optimise our ad campaigns. We may utilise third party cookies in some parts of our websites.
In using our website you consent to the use and storage of cookies on your end device. You can also view our websites without cookies. If you do not wish to receive any cookies you can set your browser to refuse cookies
8. Storage and Security of data
Any personal information that falls within the scope of this privacy policy is collected and held by us or by Permitted Recipients that we may engage or authorise to store information on our behalf. Personal information may be stored both in New Zealand and offshore.
We will take reasonable steps to protect your personal information from misuse, interference, corruption, loss or unauthorised access, modification or disclosure, including through physical, electronic and procedural safeguards. However, we cannot promise that your personal information wont’ be accessed by an unauthorised person or that unauthorised access will not occur. To the extent permitted by law, we will not be responsible for and exclude all liability arising in relation to any misuse, interference, corruption, loss or unauthorised access, modification or disclosure of your personal information.
If we provide you with any passwords or other security devices, it is important that you keep these secret and confidential and do not allow them to be used by any other person. You should notify us immediately if the security of these devices is breached to prevent the unauthorised disclosure of your personal information.
If we become aware of any breach involving your personal information, we will comply with the requirements of the Act relating to the reporting of privacy breaches
9. How long do we retain your personal information?
Your personal information is kept for as long as it is required for the purposes for which it was collected, so that we may need to answer queries or resolve problems, provide improved and new services, and comply with our contractual and legal requirements.
When the personal information that we hold is no longer required or is not required to be retained by law, we will destroy, delete or permanently anonymise it (except for any personal information that is stored on an off-site server or electronic backup data that cannot be readily accessed).
10. Email and other electronic communications
We are committed to full compliance with the Unsolicited Electronic Messages Act 2007.
In using our website and other online and digital channels and/or by providing us with your personal information you consent to receiving communications from us or from Permitted Recipients using the contact details you have provided (including, without limitation, email, SMS, telephone call, and other phone number-based messaging) which promote and market our products and services, from time to time.
You can opt out of those communications at any stage by contacting us using the contact details set out below at paragraph 11 or by utilising the "unsubscribe" facility included on all such communications. Once you have unsubscribed from these communications, we will remove you from the corresponding marketing list as soon as is reasonably practicable.
11. Your rights to access and correct personal information
You may obtain confirmation from us as to whether or not we hold personal information about you. You also have a right to access personal information about you if we hold that personal information in a way that it can be readily retrieved.
You can make access requests in relation to your personal information by contacting our Privacy Officer using the details set out below. Please quote your name and address and, if possible, provide brief details of what information you want a copy of (this helps us to more readily locate your information).
We will provide you with access to your personal information unless we are required or authorised to refuse such access by law. Please note that we will not be able to the disclosure of the affairs of another individual.
There may be a reasonable charge associated with retrieving and providing a copy of your personal information to you. We will advise you of this prior to sending your information.
You can also request correction of or amendment to the information held by us at any time by contracting our Privacy Officer using the details set out below and specifying the information that you would like changed. If it is reasonable in the circumstances for us to do so, we will make the requested change or correction, otherwise we will take reasonable steps to mark that information as having been subject to a change or correction request.
All such enquiries should be directed to:
Privacy Officer, Penrose Motors Limited, PO Box 112100, Auckland, 1062
Email: [email protected] Phone: 09 571 3151
12. Complaints
We will strive to ensure that your personal information is treated confidentially and in accordance with the Act. However, if you have any questions or complaints about the handling of your personal information, please contact our Privacy Officer in the first instance using the contact details set out in paragraph 11 above and we will do our best to assist.
If you are still not satisfied, you can make a complaint to the Privacy Commissioner. Further details on how to do this are available on the Privacy Commissioner website at www.privacy.org.nz.
13. Changes to this privacy policy
We reserve the right to amend this privacy policy from time to time by posting an updated privacy policy here on this website. We recommend that you regularly review this privacy policy when you visit this website.
If you do not agree with any aspect of the updated privacy policy, you must promptly notify us.
This privacy policy was last updated on 24th June 2021.
15. Privacy Act
Any reference in this privacy policy to the “Act” is a reference to the Privacy Act 2020 including any amendments, re-enactments or replacements of that Act.
Nothing in this privacy policy affects your rights under the Act. Further information about the Act and how it protects the personal information of individuals in New Zealand is available from the Privacy Commissioner website at www.privacy.org.nz.
Penrose Motors Ltd (also referred to as “our” or “us” or "we") is committed to protecting the privacy of personal information of our current, former and potential customers (also referred to as “customers” or “you” or “your”) and to complying with our obligations to you under the Privacy Act 2020 (“Act”).
This privacy policy describes how we will manage your personal information held by us, including how we collect, use, hold, disclose and otherwise process that information. You will also find information about how to contact us if you have any queries, including how to update or access your personal information or make a complaint.
By providing us with your personal information (whether directly or indirectly) you accept and consent to the provisions of this privacy policy. If you have any questions or concerns regarding this privacy policy, please contact us.
It is important to note that, if we are unable to collect, use, hold, disclose and otherwise process your personal information in the manner authorised by this privacy policy then we may not be able to provide you with the services we provide.
2. The types of personal information we collect.
Below we have described some examples of the types of personal information that may be collected, however this may not be an exhaustive list:
- Your name and contact details, including physical and postal address, email addresses, phone numbers, mobile numbers, and driver’s license if you loan a car.
- Financial and credit information if you apply for finance via one of our 3rd party providers.
- Information about your vehicle, including its number plate, vehicle identification number (VIN), NZTA data, and service history where available.
- If you request or receive roadside assistance services, we may collect information about where (e.g. location) and when (e.g. date, time) you requested roadside assistance services and the assistance service that is required.
- Recordings of you from our Closed-Circuit Television (CCTV) security system.
- Information about your use of or interest in the services that we provide, for example enquiry details, your feedback or opinion on products and services, and records of your communications with us.
- Information that you share as part of your public profile on a third-party social network, or information you create and share with us by posting it to one of our social networks.
- Information relating to the way you use or navigate any of our websites, customer portals and mobile applications so that we can improve your experience and our communications with you online.
- Other personal information that we are permitted or otherwise required by law to obtain, as well as any other information that you choose to provide us.
3. The ways in which your personal information is collected.
We collect personal information from or about you in a variety of ways. Where possible we will collect personal information directly from you. We may also collect information from persons you have authorised to share your personal information with us, or from whom you authorise us to collect personal information. The most common ways we collect personal information are:
- from you directly either in person, over the phone, by email, or through our digital and online channels, for example. when:
- you make an enquiry about services, parts, or accessories:
- if you interact with us online, including via our websites or through our social media channels;
- if you enter a promotion or competition carried out by us or by a third party with official affiliation or support from us;
- from the Motor Vehicle Register, in accordance with our authorisation to access this register for specified purposes under section 241 of the Land Transport Act 1998;
- from any third-party provider of motor vehicle finance;
- from other third parties, including our business associates, service providers, contractors, and agents.
4. Why we collect personal information and what we do with it
We, and the Permitted Recipients referred to in paragraph 5, may collect, hold, use and disclose and otherwise process your personal information for the following purposes (and for any related purposes which you would reasonably expect):
- to enable us to correspond with you and do business together and for reasons related to our business operations, such as to ensure we continue to deliver quality services to our customers and potential customers;
- to administer or assist in administering your ongoing vehicle service, and enabling us to obtain required parts on a timely basis to meet your needs;
- to facilitate your application for finance for the service of your vehicle;
- to facilitate your application to open a trade account with us;
- to lodge or assist in an insurance claim;
- if you have a credit history with us, to provide trade references on your behalf;
- to respond to your enquiries, comments, concerns or requests for information about parts, accessories, services;
- to process sales orders and administer accounts, and vehicle service records;
- for product development, market research, and customer surveys (for example, to obtain your feedback and find out your level of satisfaction with our services);
- for marketing and promotional activities, including to contact you directly or through authorised service providers;
- to compile aggregate data and generate reports and data about our service usage patterns;
- to carry out our legal compliance obligations;
- to send you service and Warrant of Fitness reminders;
- to contact you with details new services offered by us or by other parties, or special offers or promotions, that we think may be of interest to you;
- we may use information collected from our websites to enable the features of the websites, to improve the websites by determining which of our products, features and services are most popular, and to personalise the experience of the users of our websites;
- for other purposes which are disclosed to you, and to which you consent, whether expressly or by implication by providing us with your personal information with knowledge of how we intend to use it; and
- without your consent for purposes that are required or authorised by or under any applicable law.
5. Who has access to your personal information?
We respect the privacy of your personal information and will take all reasonable steps to keep it strictly confidential. However, we may disclose your personal information to third parties if required in connection with one or more of the purposes set out in paragraph 4 of this privacy policy. This may include disclosure to the following persons (in each case, a “Permitted Recipient”):
- our employees, officers, contractors, suppliers, service providers; (for example, marketing agencies, financiers, website and data hosting providers, online messaging providers, data analytics providers, and other IT suppliers);
- our affiliated or related entities and their respective employees, officers, contractors, suppliers, service providers, agents, partners, and licensees;
- our accountants, insurers, lawyers, and other professional advisors;
- if your vehicle is provided by your employer as part of a corporate or government fleet policy, we may also disclose personal information to your employer;
- any other third parties to whom you direct or permit us (whether expressly or by implication) to disclose your personal information (e.g. third parties with whom we have directly or indirectly arranged services for your benefit);
- third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
- as otherwise permitted or required by or under any applicable law.
In each case, the disclosure of personal information to a Permitted Recipient may be made directly by us to a Permitted Recipient or by a Permitted Recipient to another Permitted Recipient (for example, Manufacturers may disclose personal information directly to their suppliers).
A Permitted Recipient of your personal information shall only be entitled to use your personal information as required for the purposes for which it was provided to them, which shall be consistent with the purposes described in this privacy policy.
6. Disclosure of personal information outside of New Zealand
Some of the Permitted Recipients to whom we disclose personal information may be located outside New Zealand. Our websites and systems may be based on servers located outside of New Zealand. Please note that the privacy laws of countries outside of New Zealand may not be as comprehensive as the laws of New Zealand. In addition, if a Permitted Recipient is in a jurisdiction outside of New Zealand, the information held by that Permitted Recipient may be subject to that jurisdiction, including access requests from government, courts or law enforcement in that jurisdiction.
If we disclose personal information to third parties based offshore, we will comply with the requirements of the Act that relate to the transfer of personal information offshore.
7. Use of Cookies
Our websites use back-end techniques known as cookies to record the preferences of visitors and enable websites to be optimised. A "cookie" is a data element that a website transfers to your computer for record keeping and experience customisation. User’s computers store cookies for a time determined by the user’s browser settings.
"Cookies" are IT industry standard and help to monitor the effectiveness of advertising and how people use our websites. With usual website usage website "cookies" do not store your email address or other personal information about you unless you have given your consent, or if it is essential for technical reasons (i.e. secure login). The technology is used to generate statistics and measure website activity to improve the efficiency of customer visits and help with ad campaigns. We may also use analytics data supplied by third party vendors to inform and optimise our ad campaigns. We may utilise third party cookies in some parts of our websites.
In using our website you consent to the use and storage of cookies on your end device. You can also view our websites without cookies. If you do not wish to receive any cookies you can set your browser to refuse cookies
8. Storage and Security of data
Any personal information that falls within the scope of this privacy policy is collected and held by us or by Permitted Recipients that we may engage or authorise to store information on our behalf. Personal information may be stored both in New Zealand and offshore.
We will take reasonable steps to protect your personal information from misuse, interference, corruption, loss or unauthorised access, modification or disclosure, including through physical, electronic and procedural safeguards. However, we cannot promise that your personal information wont’ be accessed by an unauthorised person or that unauthorised access will not occur. To the extent permitted by law, we will not be responsible for and exclude all liability arising in relation to any misuse, interference, corruption, loss or unauthorised access, modification or disclosure of your personal information.
If we provide you with any passwords or other security devices, it is important that you keep these secret and confidential and do not allow them to be used by any other person. You should notify us immediately if the security of these devices is breached to prevent the unauthorised disclosure of your personal information.
If we become aware of any breach involving your personal information, we will comply with the requirements of the Act relating to the reporting of privacy breaches
9. How long do we retain your personal information?
Your personal information is kept for as long as it is required for the purposes for which it was collected, so that we may need to answer queries or resolve problems, provide improved and new services, and comply with our contractual and legal requirements.
When the personal information that we hold is no longer required or is not required to be retained by law, we will destroy, delete or permanently anonymise it (except for any personal information that is stored on an off-site server or electronic backup data that cannot be readily accessed).
10. Email and other electronic communications
We are committed to full compliance with the Unsolicited Electronic Messages Act 2007.
In using our website and other online and digital channels and/or by providing us with your personal information you consent to receiving communications from us or from Permitted Recipients using the contact details you have provided (including, without limitation, email, SMS, telephone call, and other phone number-based messaging) which promote and market our products and services, from time to time.
You can opt out of those communications at any stage by contacting us using the contact details set out below at paragraph 11 or by utilising the "unsubscribe" facility included on all such communications. Once you have unsubscribed from these communications, we will remove you from the corresponding marketing list as soon as is reasonably practicable.
11. Your rights to access and correct personal information
You may obtain confirmation from us as to whether or not we hold personal information about you. You also have a right to access personal information about you if we hold that personal information in a way that it can be readily retrieved.
You can make access requests in relation to your personal information by contacting our Privacy Officer using the details set out below. Please quote your name and address and, if possible, provide brief details of what information you want a copy of (this helps us to more readily locate your information).
We will provide you with access to your personal information unless we are required or authorised to refuse such access by law. Please note that we will not be able to the disclosure of the affairs of another individual.
There may be a reasonable charge associated with retrieving and providing a copy of your personal information to you. We will advise you of this prior to sending your information.
You can also request correction of or amendment to the information held by us at any time by contracting our Privacy Officer using the details set out below and specifying the information that you would like changed. If it is reasonable in the circumstances for us to do so, we will make the requested change or correction, otherwise we will take reasonable steps to mark that information as having been subject to a change or correction request.
All such enquiries should be directed to:
Privacy Officer, Penrose Motors Limited, PO Box 112100, Auckland, 1062
Email: [email protected] Phone: 09 571 3151
12. Complaints
We will strive to ensure that your personal information is treated confidentially and in accordance with the Act. However, if you have any questions or complaints about the handling of your personal information, please contact our Privacy Officer in the first instance using the contact details set out in paragraph 11 above and we will do our best to assist.
If you are still not satisfied, you can make a complaint to the Privacy Commissioner. Further details on how to do this are available on the Privacy Commissioner website at www.privacy.org.nz.
13. Changes to this privacy policy
We reserve the right to amend this privacy policy from time to time by posting an updated privacy policy here on this website. We recommend that you regularly review this privacy policy when you visit this website.
If you do not agree with any aspect of the updated privacy policy, you must promptly notify us.
This privacy policy was last updated on 24th June 2021.
15. Privacy Act
Any reference in this privacy policy to the “Act” is a reference to the Privacy Act 2020 including any amendments, re-enactments or replacements of that Act.
Nothing in this privacy policy affects your rights under the Act. Further information about the Act and how it protects the personal information of individuals in New Zealand is available from the Privacy Commissioner website at www.privacy.org.nz.
