Mercedes-Benz Australia Privacy Policy: Ensuring Your Data Security at LSH Auto

1. Introduction

LSH Auto (Sydney) Pty Ltd ACN 604 103 915 and our affiliates (referred to as LSH Auto, we, us or our) are committed to respecting your privacy. As a premier Mercedes-Benz dealer in Australia, we adhere strictly to the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles, and this comprehensive privacy policy (Privacy Policy). In this policy, “personal information” aligns with the Privacy Act’s definition, encompassing any information or opinion about you that makes you identifiable.

This Privacy Policy provides a detailed overview of our practices concerning the handling of your personal information within the context of Mercedes-Benz services in Australia. It clarifies how we manage the collection, storage, utilization, and disclosure of your personal information. Should you have any inquiries or complaints regarding our management of your personal information at Mercedes-Benz Australia dealerships operated by LSH Auto, please do not hesitate to contact us.

While this Privacy Policy aims to cover the majority of personal information we handle, it is not exhaustive. Specific purposes for data collection may be communicated to you at the point of collection, in which case, we will manage your information according to those specific terms. Your engagement with our websites, social media platforms, products, and services related to Mercedes-Benz Australia may also be governed by supplementary policies and terms of use, which could, in certain instances, supersede this Privacy Policy. For any clarifications about our data handling practices, especially concerning Mercedes-Benz Australia services, please reach out to us.

LSH Auto operates as an “APP Entity” under the Privacy Act, making us fully compliant with the Australian Privacy Principles, without any general exemptions applicable to our operations or practices within Mercedes-Benz Australia.

If you disagree with any aspect of this Privacy Policy, you must immediately cease using our websites, including www.mbsydney.com.au and www.amgsydney.com.au (Websites), and our social media platforms, products, and services related to Mercedes-Benz Australia (collectively termed “Services”).

2. Collection, Holding, and Use of Personal Information

INFORMATION WE COLLECT

We prioritize collecting your personal information directly from you, unless it is impractical or unreasonable to do so. The information we collect is limited to what is reasonably necessary for our operations and activities as a Mercedes-Benz dealer in Australia.

To effectively provide you with our Services, which include sales, servicing, and support for Mercedes-Benz vehicles in Australia, we collect a range of personal information:

Information Provided Directly by You: This includes information you provide when interacting with our Mercedes-Benz Australia services, such as:
- Your name, email address, telephone number, occupation, vehicle registration details, driver’s license details, financial information, and details about your current and past vehicles. The precise information we collect depends on the nature of your interaction with Mercedes-Benz Australia through LSH Auto. This collection often occurs when you use our Services, participate in promotions or competitions, visit us for test drives or vehicle purchases, arrange for vehicle servicing or repairs at our Mercedes-Benz Australia service centers, or apply for employment with us.
- Your credit card details, bank account information, and/or billing information, which are necessary for processing transactions when you purchase Mercedes-Benz products or services from us. Importantly, credit card details are not stored by us in any form, nor are they kept on any databases accessible to us, ensuring your financial security when dealing with Mercedes-Benz Australia through LSH Auto.
- Any other information you voluntarily provide to us. For instance, when you contact us via telephone, email, or SMS, we collect your contact details and any additional information you choose to share.
Website Usage Information: We also gather data about your interactions with our Website. Details about this collection and usage are available in the “Website Usage, Tracking Information and Cookies” section below, ensuring transparency in our online data practices related to Mercedes-Benz Australia.

We generally avoid collecting “sensitive information” (as defined in the Privacy Act). If such information is provided to us, we do not retain it, reinforcing our commitment to minimizing data collection within our Mercedes-Benz Australia operations.

When we collect your personal information, we are committed to transparency. We will take reasonable steps to ensure you are aware of: the purposes for collection, the types of organizations to whom we might disclose this information, whether disclosures to overseas recipients are likely (and if so, which countries), any legal requirements for this collection, and the main consequences if you choose not to provide the information. This Privacy Policy provides these details as they generally apply; however, specific circumstances might necessitate different details depending on our interaction with you as a Mercedes-Benz Australia customer. If we do not provide additional details, the information in this Privacy Policy will apply.

Failure to provide requested personal information may affect our ability to serve you effectively. For example, we might be unable to respond to your inquiries or provide the Mercedes-Benz Australia services you seek. Typically, there are no Australian laws or court/tribunal orders mandating the collection of your personal information by us.

In certain situations, we might collect personal information about you from third parties. In such cases, we will take reasonable steps to inform you about the collected information and the circumstances of its collection. These third-party sources may include:

Other entities within the LSH Auto corporate group. The Privacy Act permits the sharing of specific personal information within our corporate group, facilitating efficient operations across our Mercedes-Benz Australia network.
Customers or other individuals who provide information about you, such as joint vehicle owners, family members, or referees.
Third-party suppliers, such as roadside assistance providers, who may interact with you in relation to your Mercedes-Benz vehicle in Australia.
Publicly available sources, including data aggregators, public databases, commercial providers, and online platforms like social media. This might include your name, demographics, interests, and other publicly accessible data, which we (or our service providers) may combine with information collected directly from you to enhance our understanding of Mercedes-Benz Australia customers. We may also link your digital service usage over time with your personal information, especially if you have logged in, followed an email link, or are otherwise identifiable to us.
Austroads Ltd’s National Exchange of Vehicle and Driver Information System, particularly if we are conducting a recall related to your Mercedes-Benz vehicle in Australia.
Government bodies, including enforcement or regulatory authorities, as required by law.

If you provide personal information to us about other individuals (e.g., joint owners, family members, referees), you must inform them that you are doing so, provide our contact details, and direct them to this Privacy Policy for further information. We will proceed with the understanding that you have undertaken these steps.

3. Use of Information

We primarily use your personal information for the purpose for which it was collected and for related purposes that you would reasonably expect, especially in the context of Mercedes-Benz Australia services. These purposes include:

To deliver requested products and services, respond to your inquiries, provide requested information, or generally fulfill the purpose for which you provided the information to us regarding Mercedes-Benz Australia.
To facilitate the sale of our Mercedes-Benz products and services, or those of third parties, within Australia.
To set up and manage customer accounts and profiles, and to identify our customers, potential customers, and their representatives within the Mercedes-Benz Australia context.
To maintain user details and profile information for ongoing service and support related to Mercedes-Benz Australia.
To contact you with invitations to events (such as new Mercedes-Benz model launches in Australia) or to inform you about new Services we offer.
To send you marketing materials about new Mercedes-Benz Services and offers that we believe may interest you, and to conduct market research and promotional activities related to Mercedes-Benz Australia.
To improve our Services, such as conducting customer satisfaction surveys after you purchase or service a Mercedes-Benz vehicle with us in Australia.
To provide customer support, including addressing your concerns and resolving any disputes related to Mercedes-Benz Australia services.
To assist in our future planning through administrative purposes such as statistical analysis (typically using de-identified data).
To verify the accuracy of information you provide by comparing it with third-party sources.
To engage in other activities as required or permitted by law.

Should we intend to use your personal information for purposes other than those outlined above, we will generally seek your consent, unless legally permitted to proceed without it. This ensures that we maintain your trust and comply with privacy regulations in Australia, especially concerning your interactions with Mercedes-Benz Australia through LSH Auto.

4. Storage and Security

We are committed to taking reasonable steps to secure your personal information and protect it from misuse, interference, loss, unauthorized access, modification, or disclosure. This is paramount in maintaining the trust of our Mercedes-Benz Australia customers.

Our stored information is safeguarded by comprehensive security access policies and procedures. For example, personal information collected and stored on our computer network is housed on secure servers accessible only to personnel who require access for their business functions. We also maintain robust physical security measures to protect tangible (hard-copy) records containing personal information related to Mercedes-Benz Australia operations.

Regular monitoring of our practices, procedures, and systems is conducted to ensure the effectiveness of our security policies and to implement improvements as needed. However, it is important to acknowledge that no method of data transmission or electronic storage is completely infallible. We cannot guarantee absolute data security, particularly when transmitted via the Internet or third-party platforms (e.g., email or social media). Therefore, any transfer of personal information to us is at your own risk.

When we disclose your information to third-party service providers, we establish contractual arrangements that mandate them to uphold the security of your information, ensuring consistent data protection standards across all interactions related to Mercedes-Benz Australia services.

We endeavor to destroy or de-identify your personal information as soon as it is no longer necessary for our purposes, where legally permissible. Disposal of personal information is carried out securely, ensuring permanent de-identification or destruction.

5. Disclosure of Personal Information

Generally, we disclose your personal information only for the purposes for which it was collected and for related purposes that you would reasonably expect, particularly within the context of Mercedes-Benz Australia services.

Disclosure of your personal information may be made to:

Other members of the LSH Auto corporate group, as permitted under the Privacy Act for intra-group disclosures, facilitating integrated services across our Mercedes-Benz Australia network.
Third-party suppliers, including Mercedes-Benz Australia/Pacific Pty Ltd, when necessary for providing products to you and for related purposes such as administering your Mercedes-Benz manufacturer’s warranty in Australia.
Third-party financial and credit service providers, such as Mercedes-Benz Financial Services Australia Pty Ltd, if you apply for finance in connection with purchasing a Mercedes-Benz vehicle from us in Australia.
Service providers contracted by us, including IT service providers, marketing material printers and distributors, creditors, banks, financiers, credit providers, insurers, and external business advisors (e.g., auditors and lawyers), all supporting the operation of our Mercedes-Benz Australia dealership.
Third parties as necessary to detect and prevent fraud and to protect the rights, property, and safety of our business, you, and others within the Mercedes-Benz Australia community.
Third parties as required to enforce our policies and agreements.

We may disclose your personal information to overseas recipients if necessary to fulfill the purpose for which it was collected. In such cases, we take reasonable steps to ensure that the overseas recipient complies with the Australian Privacy Principles. However, typically, the only likely overseas disclosure is to our parent company in Hong Kong SAR for corporate reporting and compliance obligations related to our Mercedes-Benz Australia operations.

6. Website Usage, Tracking Information and Cookies

To enhance our Services and understand user interaction, we collect limited information from users of our Mercedes-Benz Australia websites. This helps us track resource usage, improve our Services, and analyze user navigation. We do not use these technologies to track your activity across other websites. The information we collect may include:

Details about your device and connection, such as IP address, domain names, location or device information, and data from your mobile device if used to access our Website. You can disable location tracking through your device settings if you prefer not to share this information with Mercedes-Benz Australia websites.
Data collected via integrated plugins on our Website. Where third parties collect this data, we encourage you to review their privacy policies to understand their data handling practices, as these are outside our control.
Cookie-related data. We use both first-party and third-party cookies and similar technologies on our Website. Cookies are small data files stored on your device that collect information like IP address or website usage data. More details are provided below.
Data on your Website usage, including IP address, access dates and times, page views, downloaded documents, referring URLs, and other website activities.
Search terms, interactions with other users, and other activities performed on our Website related to Mercedes-Benz Australia.

(collectively, “Usage Information”).

We may use software like JavaScript embedded in our websites and cookies placed on your device to collect Usage Information. Third-party services such as Google Analytics, Facebook Pixel, and Adobe Analytics may also be used to track Usage Information related to our Mercedes-Benz Australia products and services.

Unless you have a registered account with us, we do not link Usage Information to your personal details. For registered users, Usage Information may be associated with your registration data. For unregistered users, Usage Information is aggregated and anonymized.

You can decline cookies via your browser settings, but this might affect your website experience. Refer to your browser documentation for cookie management instructions.

GOOGLE ANALYTICS

We utilize Google Analytics Advertising Features, including remarketing, Demographics and Interests reporting, and Google Display Network Impression Reporting, to better understand and serve users interested in Mercedes-Benz Australia. These features use cookies and similar technologies to collect website traffic data. Google Analytics, as we understand, does not collect personal information or associate your IP address with other Google-held data. For more information on Google Analytics, please visit: https://analytics.google.com/analytics/web/provision/#/provision.

These features enable interest-based advertising, allowing third-party vendors like Google to display our ads on other websites across the Google Display Network and to analyze your interaction with these ads. For example, cookies help in selecting ads based on your browsing history, including previous visits to our Mercedes-Benz Australia website. Our use of Google Ads, including remarketing and audience targeting, helps us provide relevant marketing to potential Mercedes-Benz Australia customers.

By using our websites, you consent to the use of cookies for Google Analytics unless you opt out. You can opt out by installing the Google Analytics Opt-out Browser Add-on or adjusting Google Ads Settings (https://adssettings.google.com/). Note that opting out of Google Analytics may not stop all advertising, including non-interest-based ads or interest-based ads not served by Google.

FACEBOOK PIXEL

Our websites may use Facebook Pixel to track user activity originating from our Facebook advertisements, helping us measure ad effectiveness for statistical and market research related to Mercedes-Benz Australia. Facebook Pixel does not collect personal information but tracks user interactions on our website who have clicked through from Facebook ads. Data collected is managed by Facebook and may be linked to your Facebook account and used for Facebook’s promotional purposes as per their Data Usage Policy: https://www.facebook.com/about/privacy/. You may opt out of our use of Facebook Pixel through your Facebook account settings. By using our website, you consent to our use of Facebook Pixel unless you have opted out.

ADOBE ANALYTICS

We may use Adobe Analytics tools, including Analytics Workspace, to analyze website visitor behavior and optimize our website design and usability for users interested in Mercedes-Benz Australia. Adobe Analytics collects information such as IP address, referring webpage, search terms, and website usage patterns. This data is collected and stored on Adobe’s servers, and we access it for marketing and website improvement purposes. We understand Adobe Analytics does not collect personal information. For more details on Adobe Analytics, visit: https://docs.adobe.com/content/help/en/analytics/analyze/reports-analytics/reporting-interface/overview-data-collection.html.

You can limit data collection by Adobe Analytics by adjusting your browser cookie settings.

7. Third Party Links

Our Services may contain links to external websites with differing privacy practices. If you provide personal information to these sites, their privacy policies will govern the use of your information. We encourage you to review the privacy policies of any third-party sites you visit, especially if accessed through our Mercedes-Benz Australia websites.

8. Changes and Updates

We reserve the right to modify this Privacy Policy at any time. The most current version is always available on our website. We encourage you to periodically review this page for the latest updates on our privacy practices related to Mercedes-Benz Australia. The “Last Updated” date at the top of this policy indicates the latest revision date.

9. Complaints

If you believe your privacy has been breached, please contact us to discuss your concerns. Our contact details are provided below. Your complaint will be managed by our LSH Auto Australia Group Privacy Officer, who may escalate the issue internally as needed. We are committed to handling complaints confidentially and will contact you after investigation to discuss resolution options.

Please allow a reasonable timeframe for us to respond to your complaint. If you are unsatisfied with our proposed resolution, you may lodge a complaint with the Office of the Australian Information Commissioner: www.oaic.gov.au.

10. Further Information

For more information about how we manage your personal information, or for any queries related to this Privacy Policy or Mercedes-Benz Australia services, please contact us:

Igor Kogan Group Privacy Officer

LSH Auto Australia Level 1, 135 Kings Way South Melbourne Victoria 3205 Tel: (+61) 3 9133 2216 E-mail: [email protected]