Privacy Policy

John Hughes Group Privacy Policy

At the John Hughes Group (Group), your privacy is important to us. We are committed to ensuring the

confidentiality and security of your personal information.

This Privacy Policy outlines how we collect, use, disclose and protect your personal information, as required by

the Privacy Act 1988 (Cth) (Privacy Act). It also outlines how you can access and change your information, ask

a question or make a complaint.

It applies to each of the entities within the Group (Entities), which include:

Carz4u Pty Ltd; Rohanna Pty Ltd ATF The Skippers Unit Trust; Sovereign Credit Pty Ltd; Sovereign Insurance

Australia Pty Ltd; SRAC Investments Pty Ltd, and all trading brands.

In this Privacy Policy, unless the context requires otherwise, a reference to ‘we’, ‘us’ or ‘our’ is a reference to the

applicable Entity or trading brand you are dealing with from the above list.

If we are providing finance or insurance products to you, please ensure that you read the parts of this Privacy

Policy relating to credit information or sensitive information as relevant.

This Privacy Policy does not apply to our handling of personal information relating to employees or job

applicants. Please contact us if you would like further details in relation to how we handle information of that

nature.

1 Personal Information Policy

1.1 What is personal information?

Personal information is information or an opinion that identifies you as an individual or from which your

identity can be reasonably identified (regardless of whether the information or opinion is true or not, or

recorded in a material form or not). The types of information that constitutes personal information, and that we

may collect, include your name, date of birth, address and other contact information, driver’s licence number,

employment details and financial information.

In addition, if we are providing finance or insurance products to you, then we may also collect additional types of

personal information, as set out in Parts 2 and 3 of this Privacy Policy.


1.2 What is the purpose for collecting personal information?

We only collect personal information that is reasonably necessary for our business functions and activities. This

may include using your personal information to process sales or any requests you may have, notify you of

important changes to our services, comply with record keeping requirements, advise you of products and

services that may interest you (unless you have declined to receive such communications in accordance with

section 4 below) or to verify your identity.

Various laws may require or authorise us to collect your personal information. These laws include the Personal

Properties Securities Act 2009 (Cth), the National Consumer Credit Protection Act 2009 (Cth) and the AntiMoney

Laundering and Counter-Terrorism Financing Act 2006 (Cth).

We may also keep records of communications containing personal information (including recordings of

telephone calls and emails) for the purpose of staff training.

If we do not collect your personal information, we may not be able to provide you with our products or services.


1.3 How do we collect personal information?

We can only collect personal information about you by a lawful and fair means. We may collect information from

you directly, such as when you complete an application form including an online application form, a contract or

make an inquiry. We may also collect your personal information indirectly from third parties such as our related

companies, introducers, finance and insurance companies or service providers.

If we receive personal information about you from someone else without having asked for it (whether from within

the Group or from a third party), we will only continue to hold it if it is personal information that we could have

collected from you ourselves, in accordance with this Privacy Policy. We will determine whether we could have

collected the information ourselves, or if it is necessary for our business functions and activities, within a

reasonable period of time after we have received it.

If it is personal information which is not reasonably necessary for our business functions and activities, or that

we would not have obtained ourselves in accordance with this Privacy Policy, we will destroy or de-identify it as

soon as it is practicable for us to do so.


1.4 How do we collect information on our websites?

If you are using one of our websites, you will browse anonymously, except as set out below.

For all visitors browsing our website, we use cookies to collect information. A ‘cookie’ is a small text file placed

on your computer by our web page server, which can later be retrieved by our web page server. Most browsers

accept cookies by default, however you can choose if and how a cookie will be accepted by configuring your

preferences and options in your internet browser. Most browsers do allow a ‘private’ mode where cookies are

always deleted after a visit.

Please read your browser’s help section for more information about how to set the ‘private’ mode or how to

delete cookies. You can still visit our site even though your browser is in ‘private’ mode, however the user

experience might not be optimal and some functionality might not work.

Cookies may be used to collect information such as the server your computer is logged on to, your browser type

(for example, Internet Explorer, Chrome or Firefox), the time of visit, pages visited and your IP address. An IP

address is a number that is assigned to your computer automatically and required for using the Internet and we

may need to collect it for your interaction with various parts of our websites. We may also derive the general

geographic area associated with an IP address. We also use cookies to manage online advertising.

The information that we collect in this way is not capable of personally identifying you and is therefore not

personal information.

If you have provided us with personal information by completing an application form online, we retain the

information contained in that application and we may use cookies to collect information about how you browse

our websites, which can also identify you. If you would prefer not to be identified in this way, you can delete the

cookies and reconfigure the cookie preferences on your internet browser.

We and third party vendors, such as Google, use first party cookies and third party cookies together to report

how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services

are related to visits to website digital services. We use Google Analytics Advertising features (Demographics

and Interests Reports and Remarking with Analytics). Web users who do not want their data collected with

Google Analytics can install the Google Analytics opt-out browser add-on. This add-on instructs the Google

Analytics JavaScript running on websites to prohibit sending information to Google Analytics.

For marketing purposes our websites may use UTM tags. UTM tags or UTM codes are a way to analyse

website traffic or marketing campaigns from other platforms or AdWord campaigns and how you interact with

our websites. To do this a ‘tag’ is added to the end of a URL which provides data to Google Analytics.


1.5 Using and disclosing personal information

We only hold, use and disclose personal information about you for the purposes outlined in section 1.2, or for

related purposes which might be reasonably expected, unless we otherwise obtain your consent.

To do this, we may disclose your personal information to Entities within the Group or third parties outside the

Group who:

(a) are service providers to the Group (such as lawyers, accountants and storage providers);

(b) are regulatory bodies, government agencies, law enforcement bodies, courts and dispute resolution

schemes;

(c) introduce you to the Group (such as brokers);

(d) are financiers, insurers or warranty providers;

(e) are vehicle or parts manufacturers;

(f) are your authorised agents, executors, administrators or legal representatives; or

(g) are credit reporting bodies (CRBs) who may use this information to provide identity verification

services.

By agreeing to this Privacy Policy, I confirm that I am authorised to provide the personal

details presented and I consent to my information being checked with the document issuer or

official record holder for the purpose of confirming my identity.

We may also hold, use and disclose your personal information in connection with suspected fraud, misconduct

and unlawful activity, and as part of acquisitions or potential acquisitions of or by our business.

If we are holding your personal information in connection with suspected fraud, misconduct or unlawful activity,

we are not required to give you access to that personal information if we reasonably believe that such access

would prejudice the taking of appropriate action in those circumstances.

On some occasions, we may be obliged to disclose your personal information by law, e.g. court order or

statutory notices pursuant to any legislation, and to government authorities.

1.6 Government identifiers

If we collect government identifiers, such as your tax file number, we do not use or disclose this

information other than as authorised by law. We will never use a government identifier in order to

identify you.

1.7 Business without identifying you

In most circumstances it will be necessary for us to identify you in order to successfully do business with

you. However, where it is lawful and practicable to do so, we will offer you the opportunity of doing

business with us without providing us with your personal information, for example, if you make general

inquiries about interest rates or current promotional offers.

2 Credit Information Policy

2.1 What is credit information?

Where we provide finance to you, we collect, hold, use and disclose certain credit information about

individuals who are, or apply to be, customers for consumer credit, or guarantors for consumer or commercial

credit.

We may collect and hold any type of credit information about you as permitted by the Privacy Act and the

Privacy (Credit Reporting) Code 2014. We may collect this information directly from you, or from other third

parties such as Credit Reporting Bodies (CRBs). The types of credit information we may collect include:

• identity particulars such as your name, gender, address (and previous addresses), date of birth, name

of employer and driver’s licence number;

• the fact that credit has been applied for with us and the amount and type of credit;

• details of other credit providers relevant to you;

• details of the start and end dates of credit granted to you and certain terms and conditions of your

credit arrangements (such as repayment conditions);

• repayment history information (such as whether you have met payment obligations and the date of

payment);

• more specific default information, including information about payments which are more than 60 days

overdue, subsequent repayments or if you have entered into a new credit arrangement as a result of a

default;

• confirmation of previous information requests to CRBs made by other credit providers, mortgage

insurers and trade insurers;

• whether, in our or another credit provider’s opinion, you have committed a serious credit infringement

(e.g. acted fraudulently);

• the fact that credit provided to you has been paid or otherwise discharged;

• court proceedings information, personal insolvency information and credit-related publicly available

information; and

• scores, ratings, summaries, evaluations and other publicly available information relating to credit

worthiness, including personal insolvency information, which is derived by us or by CRBs wholly or

partly on the basis of the information above and which indicates your eligibility for consumer credit

(also called ‘credit eligibility information’).

Where we collect credit information from a CRB, we may use that information to produce our own assessments

and ratings in respect of an individual’s credit worthiness.

2.2 What is the purpose for collecting credit information?

We collect your credit information for the purpose of providing you with our credit services. This may include

using your credit information to form decisions as to whether to provide you with credit or credit assistance or

accept you as a guarantor, to confirm your identity, to manage and review your credit and to participate in the

credit reporting system (where credit information is usually exchanged between credit providers and CRBs.

2.3 How do we collect credit information?

We collect credit information in the same way that we collect personal information, as outlined in section 1.3

above.

In addition, we may collect credit information from other credit providers, from CRBs or from the usage and

repayment of any account you hold with us. If you are a guarantor, this may include obtaining from a CRB credit

reports containing personal information about you and any other information deemed necessary to assess

whether to accept you as a guarantor for the credit applied for or given to the applicant.


2.4 Using and disclosing credit information

We only hold, use and disclose your credit information for the purposes outlined in section 2.2, or for related

purposes which might reasonably be expected, unless we otherwise obtain your consent.

To do this, we may disclose your credit information to Entities within the Group, or third parties outside the

Group including those who:

• are considering becoming a guarantor or a person considering offering property as security for the

credit in order for them to determine whether to act as guarantor, or to keep that person informed

about the guarantee;

• undertake debt collection in relation to the credit;

• are named in an application for credit or guarantee, such as your employer;

• are a transferee from us of the credit;

• are parties involved in loan securitisation arrangements;

• provide credit or other products to you or to whom an application has been made for those products;

• may want to market products to you (unless you have declined to receive such communications in

accordance with section 4below);

• are involved in managing or administering your finance such as third party suppliers, printing and

postal services, call centres, trade insurers and CRBs;

• we are legally authorised to do so by law, such as under the Anti-Money Laundering and Counter

Terrorism Financing Act 2006 (Cth), government and law enforcement agencies or regulators; or

have an interest in your finance or our business.

Further, we may disclose your credit eligibility information to another credit provider in order to assess your

credit application or a guarantor application, to help you avoid a default or to tell them of any default you may

have had, but only with your consent.


2.5 Disclosure of credit information to CRBs

We may exchange your personal information with CRBs for purposes such as those described in section 2.2

or where the Privacy Act permits us to do so. For example, if you fail to meet your payment obligations in

relation to consumer credit provided by us or if you commit a serious credit infringement, we may be entitled

to disclose this to CRBs. We may also exchange other information, such as your identification details, what

types of loans you have and how much you have borrowed.

CRBs may include credit information provided by us in the reports given to other credit providers to assist them

in assessing your credit worthiness.

We share credit information with the following CRB:

Equifax Australia Information Services and Solutions Pty Ltd: www.equifax.com.au/contact-us

Equifax’s policy about the management of credit-related personal information can be found at

www.equifax.com.au/credit-reporting-policy. Equifax’s contact details are as follows:

Phone: 1300 762 207

Mail: Equifax – Customer Resolutions

PO Box 964

North Sydney NSW 2059

Email:corrections@equifax.com.au

Additional obligations, privacy consents and notifications may also apply for our credit products. This Credit

Reporting Policy is not intended to limit or exclude these provisions.


2.6 Opting out of CRB direct marketing pre-screenings

A CRB may use your credit reporting information to assist us to “pre-screen” you for direct marketing by us. If

you do not want any of the CRBs listed above to use your information for the purpose of pre-screening, you

have the right under the Privacy Act to contact them and request that they exclude you.


2.7 If you are a victim of fraud (including identity-related fraud)

You are entitled under the Privacy Act to request that a CRB not use or disclose credit reporting information

they hold about you in circumstances where you reasonably believe that you have been, or are likely to be, a

victim of fraud, including identity-related fraud. For a period of 21 days after the CRB receives your request the

CRB is not permitted to use or disclose this information and this period is called a “ban period”. You can make

such a request to the CRB listed above at 2.5. Requesting a ban period is free of charge.

3. Sensitive Information Policy

3.1 What is sensitive information?

Sensitive information is personal information that includes information relating to your racial or ethnic origin,

political opinions, memberships in trade or professional associations, political associations or trade unions,

religious beliefs or affiliations, philosophical beliefs, sexual preferences, criminal record, health information,

genetic information that is not health information, biometric information or biometric templates.

Health information includes any information about:

• your health at any time;

• your expressed wishes regarding future health services to you; or health services to be provided

to you.

This may include details of any pre-existing illnesses, medications, results of tests and investigations (such as

Xrays or blood tests), visits to health service providers and their opinions and formal assessments of disability,

incapacity or injury.

It also includes any other information collected in connection with providing a health service, the donation of

body parts or genetic information that could be predictive of your, or a relative’s health.

Where we provide insurance products to you, we may collect, hold, use and disclose certain health information

about you when you are applying for insurance or when we are assessing any claim you make.


3.2 What is the purpose for collecting sensitive information?

We require your sensitive information (including your health information) in order to assess any claims for

payment under an insurance policy (including one-off or ongoing payments) relating to illness, or injury benefits,

involuntary unemployment and life benefits.

3.3 How do we collect sensitive information?

We will only collect sensitive information (such as health information) about you if you give your informed

consent and if it is reasonably necessary for our business functions and activities.

We collect sensitive information in the same way that we collect other personal information, as outlined in

section 1.3 above.

In addition, we may collect health information indirectly from a health service provider who has assessed or

treated you, such as:

• a GP or medical specialist;

• a hospital where you have received treatment; or

• a health practitioner (such as a psychologist or physiotherapist).

3.4 Using and disclosing sensitive information

We only hold, use and disclose sensitive information (including health information) about you for the purposes

outlined in section 3.2, or for directly related purposes which might be reasonably expected, unless we

otherwise obtain your consent.

For instance, we hold, use and disclose your health information to manage our products and services, manage

our relationship with you, deal with your inquiries and concerns and assess claims you may have under your

insurance policy.

To do this, we may disclose your health information to Entities within the Group or third parties outside the

Group who:

• provide related services to us, such as lawyers, accountants, insurance underwriters, researchers or

document storage providers;

• are government agencies (including Centrelink), law enforcement bodies, courts and dispute

resolution schemes; or

• are your authorised agents, executors, administrators or legal representatives.

If we use it any way which you might not reasonably expect and which is not directly related to providing or

managing your insurance policy, we will ask for your consent.

4 Direct marketing

From time to time, we may use the personal information collected from you for direct marketing purposes, such

as targeted advertising on new vehicles, maintenance, promotions, special offers and other information which

we think you may find interesting. If we do contact you in this way, it will only be in relation to matters that

customers would reasonably expect us to contact them directly about. We will ensure that our marketing

activities comply with applicable laws.

We may contact you by telephone, email or SMS for these purposes.

You acknowledge that your personal information will be disclosed to other Entities within the Group, who may

tailor marketing to you by combining personal information about you, which is held by those Entities with

personal information we have disclosed.

If you do not wish to receive any direct marketing communications from us, you may at any time decline to

receive such information by contacting us as set out in Part 8 below. You can also follow the instructions for

unsubscribing in our direct marketing communications. We will not charge you for giving effect to your request

and will take all reasonable steps to meet your request at the earliest possible opportunity.

We do not sell personal information to third party organisations to allow them to contact you for direct marketing

purposes.

We will only use your health information for the purposes of direct marketing if you have consented to us using

the information for that purpose.

5 Disclosure of information overseas

We may disclose your personal information (which may include credit-related information) to overseas entities

that provide support functions to us which may also include car manufacturers providing warranties. These are

located in China, France, Germany, Japan, Korea, Malaysia and the United States of America. You may obtain

more information about these entities by contacting us. When we do this, we make sure appropriate data

handling and security arrangements are in place to ensure that the overseas recipient does not breach the

Australian Privacy Principles.

6 Keeping personal information secure

6.1 Security

Your personal information (including your credit information and sensitive information) may be held by us in

electronic form on our secure servers and may also be held in paper form. We may use cloud storage to store

the personal information (including credit information and sensitive information) we hold about you. The

security of your information is very important to us and we have security measures to protect any personal,

credit or sensitive information that we hold.

Before disclosing personal information to a customer, we confirm the identity of that customer to prevent misuse

or unlawful disclosure of the information.

We have security measures to ensure the physical security of personal information held on our premises and

systems. When records containing personal information are no longer required, we delete the information or

permanently de-identify it.

In relation to data stored or transmitted electronically, we regularly review developments in security and

encryption technologies. Unfortunately, no data transmission over the internet can be guaranteed as

completely secure. We take all reasonable steps to protect the information in our systems from misuse,

interference, loss, and any unauthorised access, modification or disclosure.

We take reasonable steps to preserve the security of cookie and personal information in accordance with this

policy. If your browser is suitably configured, it will advise you whether the information you are sending us

will be secure (encrypted) or not secure (unencrypted).


6.2 Data breaches

A data breach occurs if personal information that the Group or its Entities hold is subject to unauthorised access

or disclosure, or is lost. We will take all reasonable steps to prevent a data breach from occurring.

A data breach will be notified to you and the Australian Privacy Commissioner (Commissioner) if:

• There is unauthorised access to or disclosure of your personal information;

• The unauthorised disclosure is likely to result in serious harm to you; and

• We have been unable to prevent the likely risk of serious harm with remedial action.

We will also conduct an assessment if it is not clear if a suspected data breach meets the above criteria. The

assessment will determine whether the data breach is an ‘eligible data breach’ that triggers notification

obligations to you and to the Commissioner.

Once you are notified about a data breach that we have assessed as an eligible data breach, you are

encouraged to take steps to reduce your risk of harm, through measures such as changing passwords and

being alert to identity fraud or scams.

7 Access and correction of personal information

7.1 Access

You are entitled under the Privacy Act to access the personal information (including credit information and

sensitive information) we hold about you and (provided that it is reasonable and practicable) to do so in a

manner that you request.

We will need to validate the identity of anyone making an access request, to ensure that we do not provide your

information to anyone who does not have the right to that information.

We will provide you access within 30 days if it is reasonable and practicable to do so, but in some

circumstances it may take longer (for example, if we need to contact other entities to properly

investigate your request).

There may be situations where we may refuse to provide you with access, such as where the information relates

to existing or anticipated legal proceedings, if the request is vexatious or if the information is commercially

sensitive. If access is refused, we will give you a notice explaining our decision to the extent practicable and

your options to make a complaint.

We do not usually charge you for access to your personal information. However, if the request is complex, we

may charge you the marginal cost of providing the access, such as staff costs of locating and collating

information or copying costs.

7.2 Correction

If you feel that the personal information (including the credit information and sensitive information) we hold

about you is incorrect, you are able to contact us at any time to request that we correct that information.

If you would like to do so please contact our Privacy Officer using the contact details in Part 8 below.

If appropriate we will correct the information at the time of the request. Where reasonable, and after our

investigation, we will provide you with details about whether we have corrected the personal information. We

may need to consult with other entities as a part of our investigation (including other credit providers or CRBs).

We will normally try to resolve correction requests within 30 days of you making a request.

There will be no cost to you if we correct your personal information held by us.

8 Complaints

If you believe that we have not complied with our obligations relating to your personal information

(including your credit information and sensitive information), please contact our Privacy Officer as follows:

By phone: (08) 9415 0000 between 9am and 5pm Monday to Friday

By mail:

Privacy Officer

PO Box 273

Victoria Park WA 6979

By email: privacy@johnhughes.com.au

We will investigate your complaint and respond within 30 days with a proposed resolution.

If you feel we have not properly dealt with a complaint, you may contact the Office of the Australian Information

Commissioner at enquiries@oaic.gov.au or on 1300 363 992.

9 Updates

We may review and amend this Privacy Policy from time to time to address changes to laws and to reflect our

current operations and practices.

You can obtain a copy of the current version on request.