Privacy Policy

1.1          This policy relates to the operations of Crestwood EF Pty Ltd ABN 39 626 611 907 trading as “Crestwood Wheels Finance” (Crestwood Wheels Finance, we, us, and our). This Crestwood Wheels Finance privacy policy (Privacy Policy) is provided to ensure you understand your rights and obligations when sharing your personal information with us and when accessing or using our services through the website www.crestwoodwheelsfinance.com.au : and its sub-domains (Website).

1.2          Crestwood Wheels Finance is a platform that allows you to source conditional approvals and pricing for commercial vehicle purchases.

1.3          Crestwood Wheels Finance respects the rights and privacy of all individuals and, to the extent required by law, is committed to complying with the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles.

1.4          This Privacy Policy outlines:

(a)    what is personal information;

(b)    the kinds of personal information we collect and hold;

(c)    how we operate if we can’t collect your personal information;

(d)    why we collect personal information;

(e)    how we use personal information;

(f)     how and when we will disclose your personal information;

(g)    how and when your personal information is disclosed overseas outside Australia;

(h)    our process for direct marketing;

(i)      how we make sure your personal information is secure;

(j)      how we collect Usage Data and Cookies;

(k)    how you can complain about privacy breaches; and

(l)      how to contact us about your personal information.

1.5          We may, from time to time, review and update this Privacy Policy to account for: the establishment of new or amended laws; new technology; or changes to our operations. All personal information that we hold will be governed by the most recent Privacy Policy. We will give you notice about any revisions to our Privacy Policy by updating it on our Website.

2.1          In this Privacy Policy, “personal information” has the meaning given to it in section 6 of the Act (Personal Information).  Personal Information is any information, or information that can be combined, that can be used to personally identify an individual.

2.2          Personal Information may include an individual’s name, age, gender, location, postcode and contact details (including phone numbers and email addresses). It may further include video or audio recordings of your voice or image, financial information, including credit card information and bank details. If the information we collect personally identifies you, or you are reasonably identifiable from it, then it will be considered Personal Information.

3.1          We only collect the Personal Information that is:

(a)    necessary to enable us to provide our services to our clients; and

(b)    permitted for collection by law.

3.2          This may include Personal Information such as:

(a)    first name;

(b)    last name;

(c)    email address;

(d)    mobile number;

(e)    information about your vehicle and/or the vehicle you wish to purchase, including (without limitation) vehicle type, age of vehicle, purchase details, vehicle make and model and financing details;

(f)     information about your business or work activities, including (without limitation) occupation, employer name, and Australian Business Number;

(g)    financial information, including income details, credit history, banking information; and

(h)    any other personally identifiable information that is intentionally disclosed to us by you.

4.1          We will not be able to provide our services to you if you do not disclose all necessary Personal Information to do so.

5.1          The primary purpose for collecting your Personal Information is to enable us to perform our business activities and deliver our services to you.

5.2          We generally collect Personal Information where you:

(a)    contact us through our Website;

(b)    receive goods or services from us;

(c)    submit any of our online inquiry forms, including our instant pre-approval submission form;

(d)    communicate with us via email, phone, SMS, social applications (including WhatsApp) or otherwise;

(e)    interact with our Website, social application services, content and advertising; or

(f)     invest in our business or enquire as to a potential purchase in our business.

5.3          We will only collect your Personal Information from you directly, unless it is unreasonable or impractical to do so.

5.4          We may collect Personal Information from third parties including third party companies that provide us with your contact details for business purposes, law enforcement agencies or other government entities as required by law.

5.5          We may use your Personal Information for the following primary purposes:

(a)    to contact you directly following receipt of your Personal Information to provide you with information about our services;

(b)    to provide suitable goods, services or information to you;

(c)    for record keeping and administrative purposes;

(d)    to improve and optimise our service offering and customer experience; and

(e)    to comply with our legal obligations, resolve disputes or enforce our agreements with third parties.

5.6          We may also use your Personal Information for:

(a)    secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use;

(b)    any other purpose for which we receive consent from you; or

(c)    any other purpose which is permitted or required under applicable privacy laws.

5.7          We do not trade in Personal Information.

5.8          If you wish to proceed with a formal loan application following our contact with you, we may request that you sign a privacy disclosure statement (Privacy Disclosure Statement), consenting to Crestwood EF Pty Ltd ABN 39 626 611 907 or our affiliates providing your contact details to lenders (Lender). If you do not sign the Privacy Disclosure Statement, we will not progress your application and we will not disclose your personal information to a Lender. 

6.1          We may disclose your Personal Information to:

(a)    our employees, contractors, licensees or external service providers for the operation of our Website or our business, including without limitation IT systems administrators or payment processors;

(b)    specific third parties that you authorise to receive your Personal Information, including lenders;

(c)    the police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator. For example, if we have reason to suspect that you have committed a breach of any of our terms and conditions, or have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary; or

(d)    as required or permitted by any law (including the Act).

6.2          We may provide your Personal Information to external third-party service providers that we engage to perform functions on our behalf. This includes external third party:

(a)    database hosts;

(b)    data storage and management facilities;

(c)    IT services;

(d)    payment processors; and

(e)    any external third party you authorise to receive your Personal Information.

6.3          We make no representations or warranties in relation to the privacy practices of any external third party service providers and we are not responsible for the privacy policies or the content of any external third party service provider.

6.4          Your Personal Information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

7.1          If we are required to disclose Personal Information to other overseas persons or entities, we will take reasonable steps to ensure that the overseas recipients of your Personal Information do not breach the privacy obligations relating to your Personal Information.

7.2          We use the following external third party service providers that may have servers located outside of Australia: Saleforce Lightning and Microsoft 365 Suite.

7.3          We will not transfer your Personal Information to an external third-party service provider or a country unless we believe they have adequate technical and organisational measures in place to ensure the security of your Personal Information. If you don’t agree with your Personal Information being transferred to countries, you may be unable to use the Website.

8.1          We may use your Personal Information to contact you with updates that may be of interest to you, news or promotional materials. You can opt out of receiving these communications from us at any time by clicking the unsubscribe link in the email.

8.2          These communications may be sent by email in accordance with applicable marketing laws, such as the Spam Act 2004 (Cth).

9.1          You may request access to any Personal Information we hold about you at any time by contacting us at info@crestwoodgroup.com.au.

9.2          Where we hold Personal Information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We will not charge you for making a request and will not charge you for making any corrections to your Personal Information.

9.3          If you make an access request, we will ask you to verify your identity. There may be instances where we cannot grant you access to the Personal Information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

9.4          If you believe that the Personal Information we hold about you is incorrect, incomplete or inaccurate, then you may instruct us to amend appropriately. If we do not agree that there are grounds for amendment, then we will add a note to the Personal Information stating that you disagree with it.

10.1       We will take all reasonable steps to protect the Personal Information that we hold from misuse, loss, or unauthorised access including by means of firewalls, password access, secure servers and SSL transmission. 

10.2       If you suspect any misuse or loss of, or unauthorised access to, your Personal Information, please let us know immediately.

10.3       If we suspect any misuse or loss of, or unauthorised access to, your Personal Information we may inform you of that suspicion and take immediate steps to limit any further access to, or distribution of, your Personal Information. If we determine that the breach is likely to result in serious harm to you and we are unable to prevent the likely risk of serious harm with remedial action, we will take action in accordance with the Act.

10.4       If we receive unsolicited Personal Information that we are not permitted to collect under this Privacy Policy, or within the confines of the law, we will destroy or de-identify the unsolicited Personal Information as soon as practicable if it is lawful and reasonable to do so. 

10.5       We will destroy or attempt to de-identify your Personal Information if we no longer require it to deliver our services as soon as practicable if it is lawful and reasonable to do so.

11.1       If you believe we have breached your privacy, or you have any questions or concerns about our Privacy Policy, please contact us using the email info@crestwoodgroup.com.au and provide details of the incident so that we can investigate it. 

11.2       We are genuinely committed to the rules, ethos and intent detailed in this Privacy Policy and we aim to ensure that your requests or complaints are treated confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

11.3       If you are not satisfied with the outcome of our investigation, then you may request that an independent authority investigate your complaint.

12.1       To contact Crestwood Wheels Finance about your Personal Information, this Privacy Policy or concerns or complaints, please contact us by:

(a)           email at: info@crestwoodgroup.com.au; or

(b)           post to: 175 Arden Street, North Melbourne VIC 3051.