CAROO HOLDINGS PTY LTD – PRIVACY POLICY

Caroo Holdings Pty Ltd ABN 83 631 419 433 (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our online marketplace for vehicle sales (Services) or when otherwise interacting with you.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

As a visitor to our platform looking to purchase a vehicle (Buyer):

your name;
your User ID; and
your contact details, including email address or telephone number.

As a visitor to our platform looking to sell a vehicle (Seller):

your name;
your User ID and password;
your contact details, including email address, street or postal address and telephone number; and
information submitted in placing an advertisement, for example vehicle details and pricing.

As a professional user of our platform (Dealer):

your name;
your contact details, including email address, street address and/or telephone number;
business information such as ABN and licence number;
images of you for curating your profile;
your employer and job title; and
details of any professional licences or accreditations you hold.

As a Buyer, Seller, Dealer or when you visit our mobile application or website:

your preferences and/or opinions;
information you provide to us, including through feedback, customer surveys or otherwise;
details of products and services we have provided to you and/or that you have enquired about, including saved items and searches, and our response to you;
support requests submitted to us and our response to you;
your browser session and geo-location data (including live location for use of parking service for sellers), device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using, your IP address and the domain name of your Internet service provider;
additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
any other personal information requested by us and/or provided by you or a third party, including information submitted in applying for or requesting a quote for a related product such as finance or insurance.

How we collect personal information

We collect personal information in a variety of ways, including:

Directly: We collect personal information which you directly provide to us, including when you register for an account, inquire about a vehicle, or create an advertisement , through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our mobile application or website, in emails, over the telephone and in your online enquiries.
From third parties: We collect personal information from third parties, such as from Dealership employers , where they register you as an authorised employee/user of our Services, or details of your use of our mobile application or website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

Why we collect, hold, use and disclose personal information

Personal information: We may collect, hold, use and disclose personal information for the following purposes:

As a Buyer, Seller or Dealer:

to enable you to access and use our Services and associated applications, including to provide you with a login;
to contact and communicate with you about our Services, including in response to any support requests you lodge with us or other enquiries you make with us;
for internal record keeping, administrative, invoicing and billing purposes;
for analytics, market research and business development, including to operate and improve our Services and associated applications;
for advertising and marketing, including to send you promotional information about our products and services and other information that we consider may be of interest to you;
to comply with our legal obligations and resolve any disputes that we may have;
if otherwise required or authorised by law.

When you visit our mobile application or website:

to provide our mobile application or website to you;
to contact and communicate with you about any enquiries you make with us via our mobile application or website;
if you have applied for employment with us; to consider your employment application; and
to comply with our legal obligations and resolve any disputes that we may have; and/or
if otherwise required or authorised by law.

Our disclosures of personal information to third parties

We may disclose personal information to:

Buyers, if you are a Seller or Dealer, to enable them to contact you regarding your listings;
third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) IT service providers such as EB Pearls, data storage, web-hosting and server providers such as Amazon Web Services, email marketing providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
our employees, contractors and/or related entities;
our existing or potential agents or business partners;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
individuals and organisations that advertise with us if you submit an enquiry or seek or acquire certain services through us, or a third party supplier working with that advertiser to provide those services;
where we provide information to a third party at your request (for example where you submit an enquiry), you acknowledge that your information will be handled by that third party in accordance with its privacy policy and not in accordance with this privacy policy;
third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and
any other third parties as required or permitted by law, such as where we receive a subpoena.

Google Analytics: We have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Overseas disclosure

While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia

Unless we seek and receive your consent to an overseas disclosure of your personal information, we will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles and/or we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal information in accordance with the Australian Privacy Principles.

By providing us with your personal information, you consent to the disclosure/transfer of your personal information outside Australia as set out in this privacy policy.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint.

Storage and security

We take reasonable steps and procedures to prevent unauthorised access or disclosure, , and to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Use of Google API Services (this section applies to personal information accessed through Google API Services)

We use Google’s Application Programming Interface (API) Service to enhance the features available as part of our Services.

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements (set out in the Google API Services User Data Policy).

We limit our use of the personal information that we collect to providing or improving our Services. We do not use the personal information for any other purposes.

We only transfer the personal information to others if it is necessary to provide or improve our Services or as necessary to comply with applicable law or as part of a merger, acquisition or sale of assets where we notify you of this.

We do not use or transfer the personal information for serving ads, including retargeting, personalised or interest based advertising.

These restrictions apply to the raw data we obtain from the restricted scopes and data that is aggregated, anonymised or derived from them.

We have policies and procedures in place setting out appropriate safeguards for protecting your personal information obtained with the Google APIs. We will also ensure that our employees, agents, contractors and successors comply with the Google API Services Data Policy.

Use of geo-localisation data

When using our mobile application from a mobile device, we may request permission to collect your location from your device via the permission system used by your mobile operating system.

We collect your precise or approximate location via our mobile application to make certain features of our mobile application available to you, such as the parking feature.

If you have consented to the collection of this information, you can later disable it in your mobile phone settings. If you do not provide location information to us, we may not be able to provide our Services to you.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our mobile application and website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact us at:

Caroo Holdings Pty Ltd ABN 83 631 419 433

Email: admin@caroo.com.au

Last update: 29 March 2022