Privacy Policy

Informed Sources is committed to protecting the privacy of personal information and manages personal information in an open and transparent way.

Informed Sources recognises that your privacy is very important to you and that you have a right to control your personal information. We know that providing personal information is an act of trust and we take that seriously. At Informed Sources, our policy is to respect and protect the privacy of our users, clients and employees.

You can be assured that Informed Sources will never disclose individually identifiable information to any third-party for any purposes. This means that your email address, your name and other personal details that you provide will not be given or sold to any other company for any reason.

The only exceptions to this will be:

(a)      if we are required by law to make the disclosure
(b)      we believe it is necessary to provide you with a service that you may have requested
(c)      to protect our rights or the rights of another Informed Sources user; or
(d)      to lessen a serious threat to a person’s health and safety.

This Privacy Policy is effective from 25 May 2018. From time to time, our policies and procedures will be reviewed and, if appropriate, updated. If any changes are made to this policy these will be posted on our websites.  In some cases, we will also email users notifying them of the changes in our privacy practices.

Purpose of Policy

The purpose of this policy is to set out clearly the practices, procedures and systems relating to Informed Sources’ functions and activities that:

(a)      will ensure that Informed Sources complies with the various Privacy Laws that apply in the Countries where Informed Sources carries on                  business including:

          (i)    Australian Privacy Principles (APP) as set out in thePrivacy Act 1988 (Cth);
          (ii)   General Data Protection Regulation (GDPR) (European Union) Effective 25 May 2018;
          (iii)  Personal Data Protection Act 2010 (Malaysia);
          (iv)  The Privacy Act 1993 (New Zealand); and

(b)      will enable Informed Sources to deal with inquiries or complaints from individuals about Informed Sources compliance with the Privacy Laws.

Informed Sources is bound by the requirements of the Privacy Laws, which regulates how Informed Sources may collect, use, disclose and store personal information. These laws also specify how individuals may access and correct personal information held about them.

Contents of Privacy Policy

This Privacy Policy will set out the policies for the management of personal information within Informed Sources including:

(a)      the kinds of personal information that will be collected and held;
(b)      how Informed Sources collects and holds the personal information;
(c)      the purposes for which Informed Sources collects, holds and uses and discloses personal information;
(d)      how an individual may access personal information about the individual that is held by Informed Sources and seek the correction of such                information;
(e)      how an individual may complain about a breach of the Privacy Laws that binds Informed Sources, and how that complaint will be dealt with;
(f)       whether Informed Sources is likely to disclose personal information to overseas recipients;
(g)      if Informed Sources is likely to disclose personal information to overseas recipients – the countries in which such recipients are likely to be                located if it is practicable to specify those countries in this policy.

Availability of Privacy Policy

Informed Sources will take all reasonable steps to ensure that this Privacy Policy is available free of charge electronically to such persons who may be entitled to a copy of this Privacy Policy.

If a person requests a copy of the Privacy Policy in any other particular form, Informed Sources will take such steps as are reasonable in the circumstances to give the person or body a copy in that form.

Definitions

Set out below are some of the definitions contained in the Australian Privacy Act 1988.  For further information please refer to the Australian Privacy Act 1988.  The terms below are defined differently in the various Privacy Laws set out above.  For further information or clarification, you should refer to the specific Privacy Law.

Individual means a natural person.

Personal Information means information or an opinion about an 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.

For example:  the types of information that would be personal information includes your name, contact details including your address, age and health information.

Record for the purposes of this Privacy Policy includes:

(a)      A document; or
(b)      An electronic or other device:

But does not include:

(a)      a generally available publication; or
(b)      letters of other articles in the course of transmission by post.

Informed Sources means:

and any other company that is a subsidiary of Informed Sources (International) Pty Ltd or Informed Sources (Europe) Ltd from time to time.

Sensitive Information includes:

(a)      information or an opinion about an individual’s:

          (i)     racial or ethnic origin; or
          (ii)    political opinions; or
          (iii)   membership of a political association; or
          (iv)   religious beliefs or affiliations; or
          (v)    philosophical beliefs; or
          (vi)   membership of a professional or trade association; or
          (vii)  membership of a trade union; or
          (viii) sexual orientation or practices; or
          (ix)   criminal record;

that is also personal information; or

(b)        health information about an individual; or
(c)        genetic information about an individual that is not otherwise health information; or
(d)        biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
(e)        biometric templates.

What kind of personal information does Informed Sources collect and hold?

Any personal information that you provide via our websites, the MotorMouth App or directly is collected and managed by Informed Sources.

If you provide your personal information to a third party via a link from an Informed Sources website, that information is collected and managed by those third parties. You should familiarise yourself with their privacy policy prior to deciding whether you wish to provide them with your information.

The types of personal information Informed Sources may collect includes your:

• name;
• date of birth;
• gender;
• marital status and family details;
• residential, business and postal address;
• email address;
• contact telephone numbers;
• identification details;
• testimonials or opinions;
• photos of you, your vehicle including registration plates;
• financial information, such as bank account details;
• written or verbal contact with Informed Sources, including voice recordings of telephone conversations you have had with our employees; and
• activities, including but not limited to lifestyle and other interests.

Whilst you may opt not to provide us with your personal information, you should be aware that without this personal information, we may not be able to provide you with some of the services and/or products you are seeking.

Website users

• your IP address;
• your cookie ID (if enabled)
• the date and time of your visit to our site;
• the date and time you left our site;
• the pages you accessed and documents downloaded.
• the type of browser you are using the type of operating system you are using

This information is aggregated and is used in ascertaining usage patterns on our site.  We do this to help us better understand what aspects of our services our users find the most useful and how to develop services for you in the future. For sites that include advertising, this information also helps to ensure any advertising is more relevant to your interests.

For visitors that wish to make contact with us we also provide the email facility to do so and request you enter your name, company, email address and phone number. While these fields require content you are able to remain anonymous or use a pseudonym, however this may significantly impact our ability to respond to your query.

By visiting our websites and/or providing your personal information or data to us, you consent to the terms and conditions in this Privacy Policy, unless you tell us to the contrary by contacting us.

Software application users

For those who have access to our software applications and business solutions, additional types of personal information we collect include name, contact details such as email address, title, company/employer, and details of your communications and interactions with us.

This data is collected to verify your access and/or level of access within our software applications and improve our service offers. Once you have logged onto our server, we keep a record of how you use our services. This helps us to build a profile of your movements, allowing us to tailor our services to you.

MotorMouth App users: Registered (Motormouth Members)

Once you have become a MotorMouth Member, we collect personal information about you in order to provide you with the full benefits of Membership.  When you first register for Membership, we collect information from you directly and also from time to time thereafter if you provide us additional information.  The mandatory information we collect includes:

• Name (or pseudonym);
• Mobile Number;
• Email details are optional, but are required to subscribe to periodic publications and enter some competitions.

When you register to become a MotorMouth Member or modify your existing MotorMouth profile the pages are encrypted using a digital certificate and a SSL (Secure Socket Layer) session.

MotorMouth App users: Unregistered (Non Members)

If you are not a registered MotorMouth App user, the information we collect about you remains anonymous, and we do not link it to any other personal information.

Employment Applicants (via the website)

These applications are generated in the form of an email that is dispatched to the most relevant contact/s within the Informed Sources Group.  All personal information contained within this document will be used in the assessment and progression towards employment within Informed Sources.  All unsuccessful applications will be kept on file (for future employment openings) unless otherwise requested.  Applicants should contact the closest Informed Sources office for more information regarding the privacy of their personal information.

Suppliers

We collect information from our suppliers to facilitate sourcing and purchasing products and services.  This information can be collected directly from suppliers and related service providers.

Registration for Surveys & Contests

From time-to-time we may request information from users via surveys or contests.  Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information.  Information requested may include contact information (such as name and shipping address), and demographic information (such as postcode, date of birth).  Contact information will be used and shared with the contest sponsors to notify the winners and award prizes.  Survey information will be used for purposes of monitoring or improving the use and satisfaction of our services.

If you provide us with information about any third party, you must obtain that person’s permission to give us the information and inform them that you have given the information to us.

What cookies/tracking technologies do we use?

Cookies and local storage

A cookie is a small text file that’s stored on your hard drive or mobile device when you visit one of our websites.  We, and our third-party service providers may use both persistent cookies and session ID cookies.

We use persistent cookies for the following purposes:

• to enhance and personalise your experience across our websites and applications
• provide us with aggregated information/analytics on how people use our services, and
• help determine the effectiveness of advertisements and campaigns.

Users can control the use of cookies at the individual browser level.

Clear Gifs (Web Beacons)

We also employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs) in our HTML based emails.  These are tiny graphics files that contain a unique identifier that lets us know which emails have been opened by recipients.  This allows us to understand how well customers accept certain communications and the effectiveness of our marketing campaigns.  We now also use SendGrid to manage some marketing campaigns and service notifications.

How does Informed Sources collect and hold your personal information?

Informed Sources will only collect personal information about you by lawful and fair means, and not in an unreasonably intrusive manner.

It is Informed Sources’ usual practice to collect personal information directly from you when you:

• visit or use an Informed Sources website;
• complete an online form;
• complete a hard copy form;
• complete and return to us a hard copy form that is provided with one of our services;
• speak with us, or one of our representatives directly; or
• contact us directly by telephone, via mail, e-mail or online.

Where we can, we will allow you to deal with us anonymously or by using a pseudonym.  However, in some circumstances, this may not be possible, and Informed Sources may need to collect personal information from you to provide you with a service.  In some cases, if you do not provide the required personal information we will not be able to provide you with a service.

As mentioned above your personal information may be collected automatically by our software and server systems and/or directly from your interactions/communications with us.  It can however, also be supplied to Informed Sources by your employer to provide you with authorised access to our software applications in order for you to perform your work.

In addition, we collect personal information from employees.

All of your personal information is kept in a secure environment and will be kept by us for no longer than is necessary taking into account the purpose for which the data was collected.  Informed Sources may store data for longer periods if the personal data will be processed solely for research purposes.

The retention period for each category of personal data will be set out in Informed Sources’ Retention Schedule.  Any personal data will be disposed of securely when it is no longer required by Informed Sources.

If we receive information about you from a third party and it is not information we need in respect of our business activities, we will destroy or de-identify that information (provided it is lawful to do so).

Data quality and Security

We will take all reasonable steps to ensure that your personal information is stored securely and is protected from misuse and loss and from unauthorised access, modification or disclosure.

In addition, our employees, contractors and third parties who provide services related to our services are bound to respect the privacy of any personal information held by Informed Sources.

Only employees who need the information to perform a specific job are granted access to personally identifiable information.  Our employees must use passwords, access codes and security cards to access your information.  Furthermore, all employees are kept up-to-date on our security and privacy practices through emails, company newsletters and staff meetings.  Any time new policies are added our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our customers’, suppliers’, employees’ and visitors’ information is protected.

You play an important role in keeping your personal information secure, by maintaining the confidentiality of any password and accounts used on an Informed Sources website.  Please ensure that your password is a strong password that is changed regularly.

The purposes for which Informed Sources collects, holds, uses and discloses personal information

We use your personal information for a variety of reasons including to:

• provide services to you;
• answer your inquiries and deliver customer service to you;
• enable us to undertake a credit assessment;
• maintain and improve customer services;
• meet our legal obligations;
• consider making offers for employment purposes;
• manage and resolve any legal, consumer or commercial complaints and issues;
• carry out internal functions including training; and
• conduct marketing research and analysis.

In the course of conducting our business and providing our services to you, we may disclose your personal information.

We only disclose personal information for the purposes for which it was given to us, or for purposes which are directly related to one of those purposes.  We do not give it to anyone else unless one of the following applies:

• you have consented to the disclosure;
• you would reasonably expect, or have been told, that your information is passed to those individuals, businesses or agencies; or
• it is otherwise required or authorised by law.

If we engage third-party agents or contractors, we will take all reasonable steps to ensure that they do not breach privacy requirements in relation to the information, before we share your personal information with them.

Who do we disclose your personal information to?

We may disclose your personal information to:

• another Informed Sources business or entity;
• professional advisers (such as lawyers or auditors);
• payment systems operators and financial institutions;
• upon lawful request from law enforcement agencies or government authorities; and
• any persons acting on your behalf including those persons nominated by you, executors, trustees and legal representatives.

In all circumstances where your personal information is disclosed, we will take all steps reasonable to ensure that these third-parties undertake to protect your privacy.

Direct marketing

We are committed to compliance with all laws and requirements relating to the use of your personal information.  We will only use or disclose your personal information for direct marketing purposes if you have provided your information for that purpose (and you would expect us to use the information for that purpose), or if you have provided consent for your information to be used in this way.

From time to time, we may contact you with information about products and services offered by us and our related entities and our business partners, which we think may be of interest to you.  When we contact you it may be by mail, telephone, email, SMS/text message or social media message.

Where we use or disclose your personal information for the purpose of direct marketing, we will:

• allow you to request not to receive direct marketing communications (also known as ‘opting-out’); and
• comply with your request to ‘opt-out’ of receiving further communications within a reasonable timeframe.

Informed Sources will only ever contact you if you have consented to this, and you can ask to be removed from our marketing lists at anytime by contacting us directly.

How to Opt-Out

• Email Communications

If you no longer wish to receive our email newsletters and special offers from our partners, you can click on the ‘unsubscribe’ link at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt.

You will continue to receive transaction-related emails regarding products or services you have requested/access and administrative communications, such as updates to Terms or this Privacy Policy.

• Mobile App Push Notifications and Location Data

Our MotorMouth App may occasionally send you push notifications.  You may, at any time opt-out from receiving these types of messages by changing the settings on your mobile device.  Due to the nature of the application our MotorMouth App requires location services to be ‘on’.

Employees

Informed Sources collects personal information (which may include sensitive information) from its employees (past, current and future) in order to provide a range of employment related services.

Informed Sources collects personal information directly from job applicants (and their referees) or from recruitment agencies and related service providers.  The information we collect may include your name, address contact details, employment and education history, the names of your referees and other relevant information.

This information we collect about you will be used for recruitment purposes and may be disclosed to third party service providers who provide recruitment related services to us.

How an individual may access personal information about the individual that is held by Informed
Sources and seek the correction of such information.

You can request access to the personal information we hold about you at any time, and we will provide you with that information unless we are prevented by law from giving it to you.

If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.

You will not be charged for accessing your information, although we might have to charge the reasonable cost of processing your request, including photocopying, administration and postage.  We will advise you of any fee payable before we process your request.

If you believe that your personal information is not accurate, complete or up to date, please contact us via email to privacy@informedsources.com or mail to The Privacy Officer, Informed Sources, 16 Benson Street, Toowong, Qld 4066, and we will correct this information.

How an individual may complain about a breach of the Privacy Laws that binds Informed Sources,
and how that complaint will be dealt with

If you:

(a)      have queries, concerns or complaints about the manner in which your personal information has been collected or handled by Informed Sources; or
(b)      would like to request access to or correction of the personal information we hold about you;

please write to:

The Privacy Officer
Informed Sources
16 Benson Street
Toowong Qld 4066
Email: privacy@informedsources.com

For European Union data protection purposes, Informed Sources (Europe) Ltd (company number SC384641) is our representative in the European Union.

The Privacy Officer
Informed Sources (Europe) Ltd
Glen Orchy, 15 Glenorchy Road
North Berwick, EH39 49E Scotland
Email: privacy@informedsources.com

If you consider your privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements in Australia, you can contact the Office of the Australian Information Commissioner on 1300 363 992 or visit their website at www.oaic.gov.au.

If your concerns are in regard to countries outside Australia then:

• For European Countries contact the appropriate Data Protection Authority whose contact details can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
• For New Zealand contact the Office of the Privacy Commissioner at www.privacy.org.nz
• For Malaysia contact the Department of Personal Data Protection at www.pdp.gov.my

Is Informed Sources likely to disclose your personal information to overseas recipients?

Your personal information may be disclosed to other Informed Sources entities, business partners and service providers in Australia and overseas.

The countries this information may be disclosed to will vary from time to time, but may include Australia, New Zealand, Malaysia, Singapore, United Kingdom, countries in the European Union and countries in the European Economic Area.

Your personal information may be stored in a secure and encrypted form overseas (e.g. in data storage and cloud computing facilities operated by us (or by third parties on Informed Sources’ behalf).

If Informed Sources is likely to disclose personal information to overseas recipients – the countries
in which such recipients are likely to be located if it is practicable to specify those countries in this
policy.

As stated above, the countries this information may be disclosed to will vary from time to time, but may include Australia, New Zealand, Malaysia, Singapore, United Kingdom, and countries in the European Union and countries in the European Economic Area.

Government related identifiers

Informed Sources will not adopt a government related identifier (such as a driver’s licence number) as its own identifier of an individual.