Privacy Policy

Privacy and Policy

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our service, including the Fluidauto, Flipacar and DealMyCar mobile applications, and the choices you have associated with that data.We use your data to provide and improve our service. By using our service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our End User Licence Agreement which can be accessed via the following link: https://Fluidauto.com/end-user-license-agreement/.Fluidauto Pty Ltd trading as Fluidauto and DealMyCar (Fluidauto) is committed to treating your personal information in accordance with the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles (APPs) as set out in the Act.To comply with our obligations under the APPs, Fluidauto has a privacy policy which sets out how we manage privacy in our organisation. Our privacy policy is set out in this document. Further information may be obtained by writing to Fluidauto (see below for contact details).Fluidauto will review this policy from time to time to update and continually improve our processes. If this policy is amended at any time, the updated version will be posted on our websites at fluidauto, dealmycar, flipacar or available to you upon request.

Purpose of the policy

Fluidauto takes its obligations under the Act seriously. We have privacy obligations to our users and customers who utilise the services provided by Fluidauto.

Personal Information

Personal information is defined under the Act as information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether recorded in a material form or not. Sensitive information is a type of personal information that includes health, genetic or biometric information, or information or an opinion which indicates racial or ethnic origin, religious beliefs or affiliations, membership of a trade union, profession, trade association or political association, political or philosophical opinions, sexual orientation or practice, or criminal record.For the purpose of this policy, personal information may include, but is not limited to the following:

• Name, address, email and contact details;
• Business information, including:
• Your name and the name of the business you represent, the key contact names and positions of persons within the business, and the email address, postal address, location, website address and telephone number of the business; and
• For the Customer Relationship Management (CRM), the information collected for CRM purposes and a profile of the business, including the types of cars sold, brands and services provided by the business, the trading names of the business, the type of business; and
• For segmentation and profiling purposes for FLUIDAUTO CRM, the estimated unit sales, the OEM/s you represent, market segments you operate in, number of cars or other automobiles you re-market/dispose of each year;
• Information in identification documents (e.g., Licensed Motor Car Trader # (LMCT));
• Bank account details;
• Financial information and financial status; (ASIC Business Search / Credit File)
• Transaction history, for example the number, brand and type of cars sold;
• Your image on film or photograph if you attend one of our events;
• Feedback and responses to surveys and/or promotions;
• Changes to content or preferences; and
• Information provided on our website or during communication with us.

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Collection holding and using personal information

Fluidauto does not collect personal information unless it is necessary for the operation of our service and the operation of the Fluidauto, Flipacar or DealMyCar Application.When practicable, personal information will only be collected from the individual concerned. There are a number of methods of collecting personal information directly from you, including (but not limited to):

• When you visit our websites, including (but not necessarily limited to the following:
• http://dealmycar.com.au;
• https://www.fluidatuo.co; and
• https://www.flipcar.com/dashboard or https://app-prod.flipcar.com/dashboard (referred to as the “Flipacar Control Centre”);
• When you interact with our team members, including via telephone (mobile or fixed line), the chat function on our websites or e-mail;
• In person or in writing;
• Submitting feedback on business and the industry at our request or voluntarily; and

In the course of supplying our services to you, We may also collect personal information about you by indirect means including from our clients, contractors, suppliers and other associates, and from publicly available sources. If Fluidauto collects your personal information by indirect means, we will take reasonable steps to inform you that we have collected your personal information.The type of information that Fluidauto collects about you will depend on the nature of the service provided.We collect, hold and use your personal information for the primary purpose for which it is collected. We may also use your personal information for related purposes that you would reasonably expect including:

• To identify you;
• To create and manage your user file within the Flipacar CRM, Fluidauto Application, DealMyCar Application and the Fluidauto Control Centre;
• To provide information on the Fluidauto Application, DealMyCar Application & Fluidauto Control Centre “my connections” and “other users” (enabling users and customers to network)
• For segmentation and profiling purposes for Fluidauto database to provide and improve our services;
• To provide our services & support to you;
• To improve our services and business;
• Promotional purposes and sending marketing materials to you;
• To address your complaints;
• In relation to your image on film or photograph taken at an event, to report the event, to promote such an event in future, to promote us and may be used in the publicly available website (https://www.fluidauto.co) & https://DealMyCar.com or in digital/print media relevant to promotional
• To comply with our legal obligations and other purposes authorised by the

If you do not provide us with your personal information, we may not be able to provide you with all of our services. It may also affect your use of the Fluidauto and DealMyCar websites. (However, if you do not want your personal information to be used in this way, you may opt-out by contacting us at any time.)If you provide us with personal information about another person, you must only do so with their consent and you warrant that the other person is aware of this Privacy Policy and any applicable Privacy Statement.

Disclosure of personal information

We may disclose your personal information to our employees, officers, related bodies corporate and third parties as far as reasonably necessary for the purposes set out above. The third parties to whom we may disclose your personal information include:

• Third party service providers to whom we outsource some of our functions;
• Insurers, assessors, and underwriters;
• Professional advisors and consultants (such as lawyers, accountants, and auditors);
• Government and regulatory authorities, as required by law and/or in the course of providing our services to you; and
• Website hosts & website

We may also disclose your personal information to a third party where authorised by you, where permitted/required to do so by law or where you have consented.

Disclosure to third parties

Where we disclose personal information to third parties we will take reasonable steps to ensure that they comply with the Act, including the APPs, and this policy, including, with the exception of international users, where the recipient is located overseas (unless the overseas recipient is subject to a binding legislative regime that is as effective as, or substantially similar to, the Australian privacy regime).If Fluidauto is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy. Fluidauto may disclose your Personal Data in the good faith belief that such action is necessary:

• To comply with a legal obligation
• To protect and defend the rights or property of Fluidauto
• To prevent or investigate possible wrong doing in connection with our services
• To protect the personal safety of users of our services
• To protect against legal liability Data security

Fluidauto stores information in different ways, including in hard copy or electronic format. Fluidauto will take all reasonable steps to protect personal information from loss, misuse or unauthorised access. Some of the steps that Fluidauto has taken to protect the security of your personal information include:

• Computer and network security including passwords and other electronic barriers;
• Policies for destroying or permanently de-identifying personal information no longer required (subject to legal requirements for retaining certain records);
• Restricting access to those Fluidauto employees and contractors who need it to perform their legitimate Fluidauto business activities and responsibilities;
• Confidentiality requirements of our employees, contractors and other service providers.

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Payments

We may provide paid products and/or services within the services we provide, including the Fluidauto Application and the DealMyCar Application. In that case, we use third-party services for payment processing (e.g. payment processors).We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are:• Apple Store In-App Payments

‍Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/‍Google Play In-App Payments

‍Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/‍Stripe

‍Their Privacy Policy can be viewed at https://stripe.com/privacy-shield-policy‍Website, Cookies and Web Analytics

‍Fluidauto websites at https://www.fluidauto.cowww.DealMyCar.com.auwww.flipacar.com

‍ (FLUIDAUTO websites) are hosted in Australia. When you visit Fluidauto websites we may collect certain information such as server address, browser type, operating system, website visited immediately before coming to our site, the pages you accessed on the websites, how long you visited, the date and time you visited, your geographical location and type of device used. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service. We may also use ‘cookies’. A cookie is a small file Fluidauto websites place on your computer so that they can remember your preferences and improves your experience of Fluidauto websites. You can block placement of cookies in your browser settings. You can also clear cookies from your browser. If you do this, some parts of Fluidauto websites might not work as well. Fluidauto websites use Google Analytics and Firebase which collects information about the use of the website and traffic to the website. We use Google Analytics to promote our goods and services, including by allowing us to provide advertising to you on websites not owned by us. You can choose to opt-out of Google Analytics and Firebase collecting and using your data by downloading the Google Analytics & Firebase Opt-out Browser Add- on. The Fluidauto privacy policy extends to any personal information collected from Fluidauto websites. Fluidauto websites contain links to other internet sites belonging to other parties and are not subject to FLUIDAUTO’s privacy policy. Fluidauto does not guarantee the completeness, accuracy of, or accept any responsibility for, information contained within any linked sites. You will need to contact those websites to determine their privacy policy.

Quality and Correction

Fluidauto will endeavour to ensure that the personal information we hold about you is complete, accurate and up to date. In order to assist us to achieve this, it is important that you advise FLUIDAUTO when your details change, are inaccurate or not up-to-date such as when you change address. You may contact Fluidauto at any time if you would like your details corrected. Fluidauto members can assist by ensuring that all their details are correct on membership renewal forms.

Access

Fluidauto will provide access to the personal information that we hold about you except in limited circumstances (for example, when providing access would have an unreasonable impact on the privacy of others or denying access is required or authorised by law).Requests for access to your personal information should be in writing to support@fluidauto.co. We will respond to all requests for access within 30 days. In the interest of protecting the privacy of all of our users and customers, Fluidauto must properly identify you (for example, by requiring some form of identification such as a driver’s licence or passport) before access to information is provided. If your request is accepted, access may involve you inspecting or taking notes or making photocopies of your personal information. If your request is rejected, we will provide reasons for denying access. Generally, there is no fee for access to personal information. However, Fluidauto may charge a reasonable fee for access if the information is archived or if Fluidauto has incurred administrative costs in locating and/or reproducing the information. You may contact Fluidauto on the contact details provided below at any time to request information about generally the sort of personal information Fluidauto holds, for what purposes and how it is collected, used and disclosed.

Complaint Handling Process

If you have any concerns about the way your personal information has been managed by Fluidauto you may make a complaint to us. We request that you put your complaint in writing mailed to the address or email set out below. We will investigate and respond to privacy complaints within 30 days. If you are not satisfied with the response we provide, you may contact the Office of the Australian Information Commissioner with you query or complaint.

Contact Fluidauto

If you have queries, concerns, or would like to access or revise your personal records maintained by Fluidauto, please contact

Fluidauto:

Attn: Office Administrator

Business Name: Fluidauto Pty Ltd

Address: 15-19 Claremont St, South Yarra, Victoria, 3141

support@fluidauto.cohttps://www.fluidauto.co‍

More information about the Act and the APPs is available from the Office of the Australian Information Commissioner at http://www.oaic.gov.au.