Winger Motors Limited, Winger Hamilton Limited and Winger BMW Wellington Limited, trading as Winger (referred to as “our”, “us” or “we”) is committed to protecting the privacy of the personal information of our current, former and potential customers (referred to as “customers”, “you” and “your”).
2. The types of personal information we collect
Generally, the types of personal information that we collect from or about you depends on the circumstances in which the information is collected. We have described below examples of the types of personal information that may be collected, however this is not an exhaustive list:
- Your name and contact details, including physical and postal address, email address, phone number, and mobile number.
- Financial and credit information if you are seeking to obtain finance for the purchase of a vehicle and, if you finance your vehicle with one of the finance providers listed on our website at https://www.winger.co.nz/finance/ (“Finance Providers”), details of the finance, such as the amount financed and the type of finance product.
- Details about your vehicle, including its number plate, vehicle identification number (VIN), and service plan schedule.
- Information relating to your dealings with us and with relevant distributors and manufacturers such as Subaru, Jeep, BMW, Mini, Maserati, MG, Suzuki, Hyundai, Isuzu, Alfa Romeo, and RAM (“Vehicle Brands”) (including details of vehicle/s purchased, service and repair history, and responses to questions that we ask).
- Your driver’s licence details if you participate in a test drive, you purchase a vehicle or we are given these details from you or a third party.
- Demographic information about your age, gender and occupation, as well as information about your hobbies, and other interests and preferences, when you provide us with that information. For example when you enter a competition or promotion or take part in a customer experience survey following the purchase or service of your vehicle.
- Recordings of you from our Closed Circuit Television (CCTV) system.
- Details you provide us when making enquiries or providing feedback on our products and services, including, for example, enquiry details, your opinion on products and services, and records of your communications with us.
- Details you share as part of your public profile on a third-party social network, or that 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.
- Other personal information that we are permitted or required by law to obtain, as well as any other information that you choose to provide us.
3. How we collect personal information
We collect personal information from or about you in a variety of ways. We will try to collect personal information directly from you. 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 purchase a vehicle from us or bring your vehicle to us for a service or repair or if we purchase a vehicle from you;
- – you make an enquiry about the Vehicle Brands, parts, accessories or services, or if you request a test drive, brochure, specification sheet, information or other materials about such vehicles, parts, accessories or services;
- – you interact with us online, including via our websites or through social media channels;
- – you enter a promotion or competition carried out by us directly or carried out by a third party with official affiliation with or support from us; or
- – you participate in a marketing, product development, profiling, survey or market research campaign, including on social media channels;
4. Why we collect personal information and what we do with it
We only collect personal information that we consider necessary for the effective functioning or activities of our business, and we only hold, use and disclose it for the purposes for which it was originally collected (and for related purposes which you would reasonably expect) unless required or authorised by or under law or if you have consented to another use. Some of the specific purposes for which we collect, hold, use and disclose personal information include:
- 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 products and services to our customers and potential customers;
- to assist in administering your vehicle purchase, lease, warranty, any extended service plan, or ongoing vehicle service, and obtaining required vehicles and parts on a timely basis to meet your needs;
- to facilitate your application for finance for the purchase of your vehicle;
- to facilitate your application to open a trade account with us;
- to insurance companies if we deem it to be necessary or desirable 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 our vehicles, parts, accessories, services or offers;
- to process sales orders and administer accounts, warranty records and vehicle service records;
- to provide you with necessary support;
- to attend to or assist in the servicing or repair of your vehicle, including the provision of online vehicle service and repair booking facilities;
- for product development, market research, and customer surveys (for example, to obtain your feedback and find out your level of satisfaction with our products and services);
- for marketing and promotional activities, including to contact you directly or through our (or our affiliates’) service providers and research agencies for these purposes;
- to carry out our legal compliance obligations, such as to conduct a product safety recall where necessary or inform you of a customer notification or field service action affecting your vehicle;
- to send you service and warrant of fitness reminders;
- to contact you with details of new vehicles, products or services, or automotive products offered by distributors and manufacturers of Vehicle Brands, or other special offers or promotions that we think may be of interest to you;
- 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, including but not limited to meeting our legal obligations, assisting in the investigation of a breach of an agreement or a law, assisting in law enforcement purposes, and protecting our and our customers’ business interests.
5. Who has access to your personal information?
- our employees, officers, contractors, agents, and third-party service providers (for example, mailing houses, marketing agencies, airline programme partners, market research providers, printers, insurance providers, financiers, website and data hosting providers, data analytics providers, warranty companies, and other IT suppliers);
- our related or affiliated companies and their respective employees, officers, contractors, service providers and agents (and our related or affiliated companies may disclose the personal information directly to their contractors, service providers and agents);
- the distributors and manufacturers of Vehicle Brand and their affiliated or related companies and their respective employees, officers, contractors, service providers, dealers, agents, partners, and licensees (and such persons may disclose the personal information directly to their respective contractors, service providers, dealers, agents, partners, and licensees);
- our accountants, insurers, lawyers, auditors and other professional advisors in order for us to obtain their advice;
- your employer if your vehicle is provided by your employer as part of a corporate or government fleet policy;
- any other third parties to whom you direct or permit us to disclose your personal information (e.g. third parties with whom we have directly or indirectly arranged services for your benefit);
- any other third parties that require the information for law enforcement, formal dispute resolution, or to prevent a serious threat to public safety; and
- as otherwise permitted or required by or under any applicable law.
Should we sell a part of or the whole of our business, our records of personal information will be transferred to the new business owner or any of its related or affiliated companies (as the case may be).
Where we have purchased a vehicle from you to sell through one of our dealerships, we may also disclose any service history records that we hold in relation that vehicle to any potential third party purchaser of that vehicle (including, without limitation, other vehicle dealerships).
6. Disclosure of personal information offshore
Some of the third parties to whom we disclose personal information are located outside New Zealand. For example, as above, the distributors and manufactures of the Vehicle Brands and their affiliated or related companies. In addition, our websites and systems and those of our group companies may also be based on servers located outside of New Zealand. When we disclose personal information to third parties based offshore, we will comply with the requirements of the Privacy Act that relate to the transfer of personal information offshore.
7. Storage and security of personal information
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.
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 Privacy Act relating to the reporting of privacy breaches.
8. How long we keep your personal information
We will keep your personal information for as long as it is required for the purposes for which it was collected, taking into consideration our need to answer queries or resolve problems, provide improved and new services, and comply with legal requirements.
When the personal information that we collect is no longer required or is not required to be retained by law, we destroy, delete or anonymise it.
9. You can access and correct personal information
You may obtain confirmation from us as to whether or not we hold personal information about you. You may also request a copy of the personal information and/or request that corrections or changes are made to it. You can make such 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.
In some cases, there may be a charge associated with retrieving and providing a copy of your personal information to you. If so, we will advise you of this prior to sending your information.
All such enquiries should be directed to:
- Privacy Officer
Winger Motors Limited
21 Great South Road, Epsom, Auckland
Phone: 09 5222001
10. Privacy queries or complaints
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 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.
12. Privacy Act
Our websites use a technology called cookies to record the preferences of visitors and enable us to optimise the design of our websites. A “cookie” is a small data element that a website transfers to your computer for record keeping and experience customisation purposes. The length of time that a user’s computer stores cookies is determined by the user’s browser settings. During normal website usage our 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).
We use this technology to generate statistics and measure website activity to improve the usefulness of customer visits. Third-party vendors may utilise cookies to collect information about the content you view on our websites and use that information to show and/or serve our advertisements on other websites based on a user’s prior visits to our websites and other internet activity. 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.
Some of the tags that are used on our websites include, but are not limited to, container tags (such as Google tag manager), which include retargeting tags and analytics tags. These tags provide us with aggregated knowledge and information on website behaviour and user preferences.
14. Email and other electronic communications
We are committed to full compliance with the Unsolicited Electronic Messages Act 2007.
By using our websites and other online and digital channels and/or by providing us with your personal information you consent to receiving communications from us or from third parties on our behalf using the contact details you have provided (including, without limitation, via direct mailing, email, SMS, telephone call, and other phone number-based messaging) which promote and market our products and services, or the products and services of others, from time to time.
You can opt-out of those communications at any stage by contacting us using the contact details set out below 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.
15. Links to other websites