Privacy policy
OUR PRIVACY POLICY
At THE SAFETY AND LEARNING GROUP Pty Ltd (ACN 696 938 799) (“Company”, “we”, “us” or “our”) we recognise the importance of your privacy and appreciate that your personal information is very important to you.
We are committed to complying with our obligations under the Privacy Act 1988 (Cth) (Privacy Act), and in particular the Australian Privacy Principles (APPs) contained in Schedule 1 of that Act (“APPs”) on which this Privacy Policy is based. Where applicable, the Company will handle personal information relying on the related bodies corporate exemption and the employee records exemption in the Privacy Act and any other applicable exemptions in the Privacy Act or other legislation.
In this Privacy Policy, "TSAL Group" means the Company and its related bodies corporate within the meaning of the Corporations Act 2001 (Cth). This Privacy Policy applies to all personal information collected by the Company and shared within the EV Group. Each member of the TSAL Group may collect personal information on behalf of The Safety and Learning Group Pty Ltd and is bound by this Privacy Policy.
In this Privacy Policy “personal information” has the meaning set out in the Privacy Act. Basically, personal information is information or an opinion about an individual who is reasonably identifiable.
This Privacy Policy outlines:
● the kinds of information we collect and hold about you;
● how you can deal with us anonymously;
● the kinds of sensitive information we collect;
● how we collect your personal information;
● the purpose by which and how we collect, use and disclose your personal information;
● cross border disclosure;
● when we will use your personal information for direct marketing;
● how we keep your information secure;
● how to access, update or correct your personal information; and
● how you can make a complaint in relation to how we may have managed your personal information.
This Privacy Policy applies to customers, potential customers, suppliers, service providers, dealers, agents, contractors, secondees, potential employees, temporary staff and generally does not apply in relation to our current or former employees.
1. THE COLLECTION OF PERSONAL INFORMATION
1.1 Information we collect and hold
We collect information that is reasonably necessary for, or directly related to one or more of our functions and activities. The types of personal information we collect include but are not limited to your:
● name;
● gender;
● age and birth date;
● occupation and employment details;
● contact details;
● residential and/or business address, including postcode;
● registration and driver’s licence details;
● other forms of identification used to confirm your identity;
● credit card and bank account details;
● other financial information;
● current and past vehicle information and details;
● cookies, website tracking and usage information including but not limited to Device ID, User/Cookie ID or Cookie Identifier;
● location through anti-theft vehicle tracking technology in loan and demonstrator vehicles;
● voice when we record inbound and outbound calls for quality, training and record purposes; and
● image by videos and photos at events, during market research or through security cameras;
● educational qualifications, resume and reference checks;
● personal interests; and
● personal preferences (such as your preferred vehicle specifications).
Anonymity
Where appropriate, we provide you with the option of remaining anonymous when entering into transactions with us, unless such anonymity would be considered unlawful or impracticable. If you elect not to provide us with your personal information, we may not be able to do business with you or consider you for recruitment opportunities.
Sensitive Information
Generally, we do not collect sensitive information. However, we may collect sensitive information about you (for example, health information and criminal record checks if you are applying for a job with us), if we have your express consent or if the collection is required or authorised by law.
1.2 How we collect your personal information
We take steps to ensure that we collect personal information by lawful means, and obtain your personal information in various ways, including but not limited to:
● when you contact or correspond with us;
● when you enrol or study with us;
● when you subscribe to one of our products;
● when you phone our customer support and assistance centres or require support;
● when you attend one of our premises or premises of our agents;
● if you order or purchase a product or service from us;
● if you enquire or apply to be an authorised partner or vendor;
● via our websites (including our microsites), including when you complete enquiry forms, create or use a login, attend a focus group, review a product or complete a survey, or where cookies or other web technologies are enabled;
● via social media;
● from competitions or promotions you have participated in or events you have attended;
● from publicly available sources (including commercially available sources such as data aggregators and public databases) and information you or others post about you online;
● from third party service providers;
● when you apply for work with us and during reference checks;
● from other members of TSAL Group;
● from government bodies, enforcement and regulatory authorities.
Where you provide personal information about other individuals to us (for example, joint owners, family members or referees), we rely on you to inform those individuals that you are providing their personal information to us and tell them about this Privacy Policy.
2. PURPOSE OF COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
2.1 How we use personal information
Primarily we collect personal information for the purpose declared at the point of collection and so we can provide you with the best possible experience, and in order to comply with our legal, regulatory, industry or workplace requirements. More specific purposes include but are not limited to:
● any purpose which we inform you about when we collect your personal information or to which you have provided your consent;
● any purpose relating to our products and or services;
● registering your interest or joining our mailing list;
● customer management including communicating with you about goods and services and responding to enquiries;
● customer assistance, care, contact and information;
● fulfilling and processing orders and administering accounts;
● product issues, service measures and recalls;
● marketing, event and promotional activities (including competitions and other promotions);
● reporting, market research, customer surveys, customer analysis and product development;
● accounting, billing or other internal administrative purpose;
● as part of servicing and maintenance of IT systems and applications;
● recruitment purposes;
● to protect our legitimate interests including registering a security interest on the Personal Property Securities Register or taking or responding to legal action;
● conducting background checks, including checking against sanctions lists;
● for any potential or actual sale, transfer, merger, acquisition, restructure or other dealing in respect of business or assets;
● to comply with industry, legal and regulatory requirements; and/or
● where permitted or required by law, a court or tribunal.
2.2 Disclosure
During the course of our day to day business, we may disclose your personal information to third parties outside our organisation, including but not limited to:
● those to whom you have consented we disclose your personal information, whether impliedly by your conduct, verbally or in writing;
● contracted service providers including payment service providers, advertising and marketing agencies, cookie and web technology providers, financiers, insurers, mailing houses, printers, market research and analytics providers, payroll and recruitment providers, debt collectors, IT and cloud service providers, roadside assistance providers, auditors and professional advisors;
● other members of TSAL Group, for the purposes of customer management, marketing, fulfilling orders, product development, internal administration, and providing you with seamless experience across TSAL Group entities. We rely on the related bodies corporate exemption in section 13B of the Privacy Act for these disclosures (some TSAL Group members may be based overseas, see 2.4 below);
● TSAL Group members that we share corporate services with, or who provide back office services to us or other TSAL Group members;
● manufacturers, distributors and suppliers of goods or services supplied by us or to you, or in respect of which you have made enquiries or which you get serviced or repaired with us;
● third party consultants under conditions of confidentiality for business related activities; and/or
● government agencies, enforcement authorities, regulators or other similar entities as required or permitted by law.
2.3 Sharing within TSAL Group
We may share your personal information with other members of the TSAL Group for the following purposes:
· providing you with products and services across TSAL Group entities, including where you commence a transaction with one TSAL Group member and complete it with another;
· customer management, including maintaining a single customer view across the TSAL Group to improve your experience;
· marketing, promotional and event activities conducted by or on behalf of any TSAL Group member;
· internal administrative purposes, including shared corporate services, IT systems, finance and human resources;
· reporting, analytics, market research and product development; and
· compliance with legal, regulatory and industry obligations.
We rely on the related bodies corporate exemption under section 13B of the Privacy Act for disclosures within the Safety and Learning Group. Where a TSAL Group member is not a related body corporate (as defined in the Corporations Act 2001 (Cth)), we will obtain your consent or rely on another lawful basis before sharing your personal information with that entity.
If you do not wish your personal information to be shared within the TSAL Group for direct marketing purposes, you may opt out at any time by contacting the Privacy Officer (see section 5.3 below) or by using the opt-out facility in any marketing communication you receive from an TSAL Group member.
2.4 Our Commitment to Children’s Privacy
We do not knowingly collect, use, share or sell the personal information of children, and we do not intend to transact with anyone we know to be under the age of 18. If you are under 18, you should only deal with us with the involvement of a parent or guardian. If we learn that we have collected personal information from a child, we will delete that information.
2.5 Cross border disclosure
In the ordinary course of our day-to-day business activities and those of the TSAL Group and our service providers, your personal information may be transferred, accessed, processed and/or stored in various countries which include but are not limited to Australia, New Zealand, China, India, The Philippines and other countries in which we do business and or receive operational support.
The countries in which these third parties are located will depend on the circumstances. Where we arrange for work or services to be undertaken on our behalf, that work is undertaken under conditions of confidentiality and may result in your personal information being transferred, accessed, processed and/or stored (for example, on clouds or servers) in various countries for the purpose of service delivery to us or you. Unless an exception applies in the Privacy Act, prior to disclosing personal information to overseas recipients we will take reasonable steps in the circumstances to ensure that the overseas recipient adheres to the APPs. An overseas recipient may not be required to protect your information in a way that, overall, provides comparable safeguards to those in the Australian Privacy Laws, and overseas organisations may be required to disclose information we share with them under a foreign law, in which case, to the fullest extent permitted by law, we will not be responsible for that disclosure.
2.6 Direct marketing
Direct marketing involves us or other members of the TSAL Group communicating directly with you to promote the sale of goods and services offered by TSAL Group, by methods including mail, telephone, e-mail or SMS/IM/MMS and potentially by third parties on our behalf. We will obtain your consent (which may be express or inferred from your conduct or an existing ongoing business relationship) prior to using or disclosing your personal information for direct marketing purposes.
2.6.1 Electronic communications
Where we electronically communicate with you (excluding voice to voice communications), we comply with the Spam Act 2003 (Cth). We take steps to ensure our electronic communications are only sent with your consent, contain accurate information about us and how to contact us, and contain a functional unsubscribe facility.
2.6.2 Do Not Call Register Act 2006 (Cth)
If you have registered your private or domestic number on the Do Not Call Register, we will not contact you for telemarketing purposes except where you have expressly opted in (and you can opt out at any time). We may still contact you for non-telemarketing purposes such as product recall and fault rectification calls, appointment reminders, calls relating to payments, and calls relating to a contract we have with you.
2.6.3 Opting out
If you do not wish to receive direct marketing from us, you can opt out at any time by contacting our Privacy Officer as per the details set out in item 5.3 of this Privacy Policy or using the opt-out facility in the relevant communication. When you opt out, we will stop sending the material.
2.7 Cookies, Tracking and Retargeting Technologies
We use web technologies (such as cookies, tracking technologies and retargeting technologies) to make our webpages more user-friendly, to improve them, and to show content, offers and advertisements more suited to you. We may also use this information for reporting, customer analytics, market research and product development. If you do not wish to have cookies placed on your device, you can set your browser to reject or disable them, though some features of our website may not work as efficiently or at all. When using web technologies, data may be transmitted to recipients outside Australia.
3. SECURITY OF PERSONAL INFORMATION
3.1 Integrity and quality of personal information
We take reasonable care to ensure that personal information we use, store and subsequently destroy/delete (where relevant) meets certain quality requirements, in that the personal information is accurate, up to date and complete.
3.2 Security of personal information
While care is taken to protect your personal information, no data transmission over the internet is guaranteed as being 100% secure, and we cannot guarantee the security of any information you send to or receive from us online. Once we receive your personal information, we are required to protect it in accordance with the Privacy Act. The Company follows its own policies, guidelines and standards to secure your information, and we continually train and remind our staff of the importance of keeping information safe and secure.
We have adopted active security measures to keep your personal information safe from misuse, interference, loss, unauthorised access, disclosure and modification, such as:
● System security: our application systems are password protected and can be accessed only by authorised people; we encrypt confidential information; and security is inbuilt into the design and operations of our systems through firewalls and virus scanning tools.
● Physical security: our premises are protected against unauthorised access by way of access cards, cameras, alarms and security services.
● Data retention: if personal information is no longer required for the purpose for which we are permitted to use, disclose or legally retain it, then we will permanently remove from a record any information by which an individual may be identified in order to prevent future re-identification from the data available. We retain information as long as needed to comply with the law or our own corporate policies and procedures.
We will at no time sell, rent or trade your personal information to or with any other unrelated entity.
3.3 Notifiable Data Breaches
In the event of a data breach that is likely to result in serious harm to any individual whose personal information is involved, we will comply with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act. This includes taking steps to contain the breach, assessing whether serious harm is likely, and if so, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) as soon as practicable. We maintain an internal data breach response plan and will take all reasonable steps to minimise the impact of any breach on you.
4. FINANCE REFERRALS
If you ask us to arrange finance for your purchase, or you apply for consumer or commercial credit through us from an external credit provider, we may collect and hold credit-related information about you (such as identification and financial information) for the purpose of passing your application to that external credit provider. We do not provide credit ourselves and will only disclose that information to external credit providers with your consent, or where you have made or intend to make an application to them for credit, or where permitted by law, and we refer you to the privacy policies of those external credit providers. We may receive a commission or benefit from a credit provider to whom we refer you.
5. ACCESS, CORRECTION, COMPLAINTS AND ENQUIRIES
We take reasonable steps to ensure that information we collect, hold or disclose about you is accurate, complete and up to date.
5.1 Access to information we hold about you
At any time, you can request access to information we hold about you. We aim to respond within 30 days, and may charge a reasonable fee for information requests. There are exceptions to your right of access outlined in the Privacy Act; if an exception applies we will, where reasonable, work with you to provide access in a way that meets both our needs, and will notify you in writing of any refusal and the reasons for it.
5.2 Correction of information we hold about you
Please let us know when your details change or if your personal information needs correction or updating, using the contact details below. Before we make any amendments we will need to verify your identity.
5.3 Complaints and enquiries
If you are not happy with the way we have handled your personal information or believe we have breached the Privacy Act or the APPs, please contact us and we will try to resolve the matter with you. For security reasons, we request that complaints, requests for access to or correction of personal information or any privacy enquiries be put in writing and e-mailed or posted to: The Privacy Officer, The Safety and Learning Group Pty Ltd, PO Box 5599 Manly QLD 4179 or email info@evsafetyaustralia.com.au. We may also require proof of your identity.
For information about privacy generally, or if your concerns are not resolved to your satisfaction, please contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.
6. INFORMATION RELATING TO PROSPECTIVE, CURRENT AND FORMER EMPLOYEES
Due to the employee records exemption in the Privacy Act, this Privacy Policy does not apply to our past or current employees. However, we recognise that employee records should be handled with the utmost care and we will comply with any obligations that may apply to employee personal information under other applicable laws. If an employee has any questions relating to their employee records, they should contact the Company’s human resources department. This Privacy Policy applies to independent contractors, job seekers, secondees and work experience students.
7. CHANGES TO THIS PRIVACY POLICY AND OBTAINING A COPY
We make our Privacy Policy available on our website and will provide a copy to anyone who requests it free of charge. We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes, we will post the updated Privacy Policy and update the “Last Updated” date. Each version of this Privacy Policy will be identified by its Last Updated date.
Last Updated: 17 August 2026