1. Objective of Policy
2. Scope of Policy
(a) “Driving Solutions”, “we”, “us” and “our” means Driving Solutions International Pty Ltd (ABN 46 119 049 722) of Suite 8A Sydney Motorsport Park, Ferrers Rd Eastern Creek, NSW, 2766 and each of its subsidiaries and related entities.
(b) “You” means a customer, website user, client, email subscriber, employee, agent, member, volunteer and contractor of Driving Solutions.
4. Policy Statement
(a) Driving Solutions respects Your privacy and understands that individuals have a right to access their personal information held by Driving Solutions.
(b) Driving Solutions is committed to protecting personal information. Driving Solutions is also committed to complying with the Australian Privacy Principles set out in the Privacy Act.
(c) This policy is created in accordance with the Australian Privacy Principles and is binding on Driving Solutions.
5. What Personal Information May We Collect and Hold?
5.1 Personal Information
Generally, personal information is information or an opinion from which it is possible to determine someone's identity.
The personal information collected by Driving Solutions will vary depending on the circumstances of collection. It may include, but is not limited to, a person's contact details (name, email and/or postal address, phone number), date of birth, credit card details, drivers licence number, medical conditions, insurance details, employment history and qualifications.
Driving Solutions may from time to time collect information from You in relation to Driving Solutions’ driver training courses, coaching, product training, track days, motorsport events, and other activities. This information may include but not be limited to personal information such as Your:
(b) contact details such as Your address, phone number and email address;
(c) gender and age;
(d) motor sport experience and driving qualifications;
(e) vehicle details;
(f) club affiliations;
(g) medication/medical condition and history;
(h) history of offences and other acts which may be prejudicial to the interests of motor sport and driving; and
(i) other information specifically provided by You to Driving Solutions or which is relevant to You participating in one of Our driver training courses, coaching, product training, motorsport events, or other activities.
5.2 Sensitive Information
Sensitive information is a type of personal information that also includes information or an opinion about racial or ethnic origin, political opinions, membership of a political association, professional or trade association or trade union, religious beliefs or affiliations or philosophical beliefs, sexual preferences or practices, criminal record, health, genetic information or disability.
If it is reasonably necessary in the circumstances, Driving Solutions may also collect sensitive information such as a person's medical history, nationality, or disabilities.
6. How Your Personal Information is Collected
Driving Solutions will not collect personal information unless the information is reasonably necessary for, or directly related to Driving Solutions’ products or services. Driving Solutions will also only collect personal information by lawful and fair means.
Driving Solutions may directly collect Your personal information data through various means, including but not limited to the following:
(a) as part of Your booking for a driver training course, coaching, product training, track day, motorsport event, or other activity, product or service offered by Driving Solutions.
(b) as a result of You participating in a driver training course, coaching, product training, track day, motorsport event, or other activity, product or service offered by Driving Solutions.
(c) when You contact, or are contacted by, Driving Solutions by any medium (including but not limited to electronic, tangible and personal means)
(d) where You provide details to Driving Solutions in a consent form, waiver, survey, feedback form, incident report or any other form of document;
(e) where You engage with Driving Solutions via social media;
(f) where provided or made available by third parties (including but not limited to government entities, track operators, event managers, promoters and organisers);
(g) from Driving Solutions’ related entities, contractors, agents and employees;
(h) searches for information which is publically available;
(i) from Your use of any Driving Solutions services (including its web based services and services provided by others on behalf of Driving Solutions); and
(j) where Driving Solutions is required to do so by law.
7. Providing information
Depending on the circumstances, some types of information will be required and others may be optional. If You do not provide some or all of the information requested, this may affect Driving Solutions' ability to communicate with You or provide You with the requested products or services.
8. Collection from third parties
(a) Driving Solutions may collect personal information regarding a child from the parent or other responsible person associated with that child.
(b) In some circumstances, Driving Solutions collects information from other third parties. Examples of such third parties could include, without limitation, government entities, law enforcement bodies, track operators, event managers, and promoters.
9. Indirect Collection of Personal Information
In addition, Driving Solutions may also collect personal data indirectly about You through Your use of our services and from other third parties. Such means may include but are not limited to:
(a) placement of cookies and other electronic markers or files on Your computer; and
(b) monitoring Your usage of Driving Solutions’ services (including its web based services).
10. How we Store and Protect Your Information
(b) Some of the third party data storage and other service providers we use are located outside of Australia in countries such as New Zealand and the USA. Driving Solutions take reasonable steps to ensure that the overseas recipients of Your personal information do not breach the privacy obligations relating to Your personal information. When Your information is entered into these databases, the information may be combined or linked with other information held about You.
(c) Security of personal information is important to Driving Solutions. We have taken steps to protect the information we hold from accidental loss and unauthorised access, use, destruction or disclosure of data. Examples of security measures we have in place are staff screening, encryption and hashing; firewalling and content filtering; virus/malware scanning and protection; logging, monitoring,physical security controls and role-based access control. We will use all reasonable efforts to safeguard Your personal data. However, You should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which is transferred from You or to You via the Internet. If You suspect any misuse or loss of, or unauthorised access to, Your personal information, please let Driving Solutions know immediately.
11. How we Use Your Personal Information
The primary purpose for which Driving Solutions collects information about You is in order to provide You with our products and services. Driving Solutions collects, holds, uses and discloses Your personal information for purposes which may include but are not limited to the following:
(a) to provide products and services to You;
(b) to provide You with news, information or advice about Driving Solutions activities, products and services;
(c) to communicate with You including by email, mail or telephone;
(d) to manage and enhance our activities, products and services;
(e) to conduct competitions or promotions on behalf of Driving Solutions and selected third parties;
(f) to verify Your identity;
(g) to conduct business processing functions for operation of our websites or our business;
(h) for administrative (including billing), marketing (including direct marketing), promotional, planning, product/service development, quality control and research purposes;
(i) to respond to emergency situations involving or requiring medical treatment;
(j) to investigate any complaints about or made by You,or if Driving Solutions has reason to suspect that You are in breach of any of our terms and conditions or that You are or have been otherwise engaged in any unlawful activity; and
(k) as required or permitted by any law (including the Privacy Act).
(l) Driving Solutions may use health information to ensure that programs it operates are run safely and in accordance with any special health needs participants may require. Health information may also be kept for insurance purposes.
12.Disclosure of Personal Information
In order to achieve these purposes, Driving Solutions may disclose Your personal information to third parties as permitted by law. Such third parties may include but not be limited to the following:
(a) Driving Solutions’ service providers, agents, employees and contractors;
(b) DrivingSolutions auditors, insurers, sponsors and re-insurers;
(c) government and law enforcement agencies and regulators;
(d) investigators and assessors.
Driving Solutions may also disclose Your personal information:
(a) with Your express or implied consent;
(b) when required or authorised by law;
(c) to an enforcement body when reasonably necessary; or
(d) to lessen or prevent a threat to an individual or public health or safety.
(e) if Driving Solutions is sold or integrated with another business Your personal data may be disclosed to our advisers, or any prospective purchasers and their advisers, and will be passed on to the new owners of the business.
13. Our Website, Cookies, Marketing, Advertising and Analytics
(a) When You visit the Driving Solutions website, our systems may record certain information about Your use of the site, including the web pages visited, the time, date and duration of Your visit. Driving Solutions uses this information to help analyse and improve the performance of the website.
(d) Driving Solutions uses Facebook Custom Audiences to deliver interest based advertisements to website visitors on Facebook based on the email addresses that we have collected. We may also use information associated with website users social media accounts, such as demographic, and other information about an individual’s title, industry, organisation and interests to improve our marketing efforts if that individual connects those social media accounts to a website profile. You can opt-out of Facebook Custom Audience Ads here
(e) Driving Solutions website uses the Facebook Conversion Tracking Pixel tool. This tool allows us to follow the actions of users after they are redirected to our website by clicking on a Facebook advertisement. This allows us to measure the effectiveness of our Facebook advertising for statistical and market research purposes. The collected data remains anonymous. This means that we cannot see the personal data of any individual user. However the collected data are saved and processed by Facebook. Facebook is able to connect the data with Your Facebook account and use it for their own advertising purposes, in accordance with Facebook’s Data Use Policy found under https://www.facebook.com/about/privacy. Facebook Conversion Tracking also allows Facebook and it’s partners such as Instagram to show You advertisements on and outside Facebook. In addition a cookie will be saved onto Your computer for these purposes. To disable this function go to: https://www.facebook.com/ads/preferences
(f) Driving Solutions may send You marketing communications and information about Our, products and services that we consider may be of interest to You. These communications may be sent in various forms, including mail, SMS or email, in accordance with applicable laws. If You indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
(g) Driving Solutions will endeavour to provide You with an option to opt out of receiving further marketing and promotional materials from Driving Solutions where You disclose personal information to Driving Solutions. In addition, You may at any time contact Driving Solutions to request that any further promotional or marketing information is not sent directly to You.
14. Access and Correction
We take reasonable steps to make sure that personal information we collect, use and disclose is accurate, complete, up-to-date and relevant. If You need to access or correct any personal information we hold about You, please contact us using the ‘Contact Details’ set out below. Please provide us with as much detail as You can about the particular information You wish to access or correct, in order to help us retrieve it. We may charge You an access fee to cover our costs of providing that information to You. We will inform You of applicable fees before they are incurred.
15. Complaints, Further Information and Future Changes
If You wish to make a complaint about the way in which we handle Your personal information, or a breach of this policy, please email our Privacy Officer. We aim to respond to written complaints within 14 days from the date of receipt. If You are dissatisfied with our response, You may refer the matter to the Australian Information (Privacy) Commissioner (see www.oaic.gov.au).