1. Introduction

Armstrong’s is committed to complying with our obligations under New Zealand Privacy Laws, in particular the Privacy Act 2020 (the Act) when dealing with personal information.  This Policy sets out how we will collect, use, disclose and protect your personal information.

All references in this Privacy Policy to “Armstrong’s”, “we”, “us” and “our” are references to Rick Armstrong Holdings Limited and our related companies, including each of our subsidiaries and our local dealerships.

This Policy describes the personal information we collect, and how we store, use, process and disclose that personal information when you use our website, visit our dealerships or contact us for any reason.  Collecting this information helps us provide our products and services to you and allows us to interact with you (for example by responding to queries or complaints). It may be difficult or impossible for us to do this without access to your personal information.

2. What is personal information?

Personal information is any information about an identifiable individual. This includes information such as your name and contact details but can also include other information about you such as your IP address, financial information, or purchase history.

3. What information do we collect?

The personal information we collect depends on the type of relationship we have with you, and which of our products and services you use. Typically, we collect personal information when you:

• visit and use our website (Website User Information); or
• purchase products or services from, or otherwise visit our dealerships and interact with, us. For example, purchasing a vehicle or parts, applying for financing or insurance through us, or booking vehicle servicing and repairs (Customer Information).

This Privacy Policy applies to all types of information we collect, but each type of information is used in a different way (as described in this Privacy Policy).  In certain circumstances, we may also obtain information about you from the Motor Vehicle Register – this is described further in section 7 below.

4. Website User Information

Collection of Website User Information: We collect the following Website User Information:

• information about how you use the website (for example, traffic volumes, how often you visit the website, and time spent on our web pages);
• where you were directed to our website from, and which web pages you access on our website;
• your IP address and/or other device identifying data; and
• any other personal information that you may provide through the website, such as your name and contact details.

Purpose of Collecting Website User Information: We collect Website User Information:

• to enable the features of our website, detect unauthorised use, to improve our website by determining which of our products, features and services are most popular, and to personalise the experience of the users of our website;
• to compile aggregate data for internal and external business purposes and generate and review reports and data about our customer and service usage patterns; and
• for the purposes described in clause 5, where the information you provide through our website is also Customer Information.

Disclosure of Website User Information: We may disclose Website User Information in accordance with clause 6 of this Privacy Policy. As examples, the types of Permitted Recipients we may disclose Website Information to include:

• information technology service providers;
• our professional advisors, such as accountants or lawyers; and
• agencies who assist us with marketing and advertising services.

5. Customer Information

Collection of Customer Information: We collect the following Customer Information:

• your name and contact details (including physical and postal address, email address and telephone numbers);
• any correspondence that you have with us, including via phone calls and call recording transcripts;
• your drivers’ licence number;
• biographical information (such as household data, preferences, and demographic information);
• publicly available information on your social media accounts, for example when you interact with our social media platforms;
• information you provide to us when participating in an experiential or promotional event;
• information on the Service Plan Schedule for your vehicle(s);
• details of the vehicle(s) you own;
• financial and credit information about you shared with us by our financial service providers, credit agencies and our suppliers;
• information about your use of or interest in our products and services;
• information about your purchase history with us;
• information about your preferences to receive marketing communications from us; and
• any other information you submit or authorise to be shared with us.

Indirect Collection of Customer Information: We may collect your personal information from dealerships outside our group of companies where you purchase a vehicle that has been distributed to that dealership by one of our entities. We maintain a database of this information for the purposes of notifying you if your vehicle is subject to a recall event.

Purpose of Collecting Customer Information: We collect Customer Information:

• to provide our products and services to you and run our internal business operations;
• to compile aggregate data for internal and external business purposes and generate and review reports and data about our customer and service usage patterns;
• to establish, maintain and improve our customer relationship with you and provide you with offers, incentives, marketing programs or promotional material about us, or the Permitted Recipients, and the automotive products and services of us or our suppliers, such as brochures and newsletters;
• to more effectively market to you our vehicles, vehicle parts, accessories and services by better understanding your automotive product and service needs and preferences;
• to improve the automotive products and services we offer through customer surveys conducted by us or third parties and participation in market research studies conducted by third parties;
• to assist in administering your vehicle purchase, lease, warranty, insurance, any extended service plan, Roadside Assistance, or any other agreement you have with us, or ongoing vehicle service, including advising you of any product recalls or customer notifications with respect to your vehicle, arranging for our dealerships to obtain required vehicles and parts on a timely basis to meet your needs;
• to provide you with services you request and respond to your comments, concerns or requests for information;
• to assist our dealerships to meet your automotive product and services needs such as providing you with offers, service reminders, marketing programs or promotional materials;
• to provide you with offers and information about related automotive products offered by others which we think may be of interest to you; and
• to communicate with you, as permitted by law, and to inform you about our and third parties’ products, services and events.

Disclosure of Customer Information: We may disclose Customer Information in accordance with clause 6 of this Privacy Policy. As examples, the types of Permitted Recipients we may disclose Customer Information to include:

• finance and insurance service providers;
• our professional advisors, such as accountants or lawyers;
• agencies who assist us with marketing and advertising services;
• vehicle distributors for the purposes of managing warranty claims or vehicle recalls; and
• where required, government bodies such as NZ Transport Agency (Waka Kotahi).

6. Disclosure of your personal information

We respect the privacy of your personal information and do not disclose your personal information unless in accordance with this Policy or as required by permitted by applicable laws.  If necessary, to achieve one or more of the purposes of collection set out in this Privacy Policy, we may transfer or disclose your personal information to:

1. any of our affiliated or associated companies and to any of our, or our affiliated or associated companies’, suppliers, service providers, agents, licensees, and other business associates;
2. any other entities with which we have directly or indirectly arranged services for our or your benefit; or

• potential purchasers of our business or any part of it.

(each being, a “Permitted Recipient”).  A Permitted Recipient of your personal information shall only be entitled to use your personal information as required for the purposes for which it was provided to them. More detail on the Permitted Recipients can be found under the Website User Information and Customer Information headings (as applicable).

In some cases, Permitted Recipients may be located outside New Zealand. When that’s the case we will take steps to ensure such disclosures are permitted by the Privacy Act.

We will not sell or receive payment for licensing or disclosing your personal information.

7. Information obtained from the Motor Vehicle Register

We may obtain your name and address from the New Zealand Motor Vehicle Register pursuant to Gazette notice 2022-au4073 issued under s 241 of the Land Transport Act 1998. We will only access this information:

• to confirm you are the registered person of a motor vehicle that we propose to purchase;
• to assist us to verify a change of registered person has been completed correctly for transaction in which we are the purchaser or seller; and
• where a motor vehicle is the subject of a safety recall listed in the safety recalls portal, to contact you to advise you of any required actions in relation to the vehicle’s safe operation.

You may notify the Registrar of Motor Vehicles that you do not wish to have your name and address made available under s 241 of the Land Transport Act 1998. To do so, you can visit the following link: Revoke authorised access to my personal details (Opt-out). If you opt out of making your information available on the Motor Vehicle Register, it may impact how we can provide our services to you.

8. Email and other Electronic Communications

Where permitted, we may contact you using the contact details you have provided (including, without limitation, via direct mailing, email, SMS, telephone call, and other phone number based messaging) in connection with one or more of the purposes set out in this Privacy Policy and including to promote and market our products and services, or the products and services of others.

You can opt-out of those communications at any stage by utilising the corresponding “unsubscribe” facility. Once you have unsubscribed from our email or text communications, we will remove you from the corresponding marketing list within five working days.

9. Storage and protection of your personal information

We may record and store the personal information we collect from you. We put in place all reasonable security safeguards to protect your personal information. Any personal information about you that we hold may be stored on computer databases, in servers, in the cloud (in New Zealand or internationally) and/or in hard copy (in New Zealand) for the purposes set out in this Privacy Policy. We may also make parts of our CRM system accessible to our Permitted Recipients such as suppliers, service providers and other business associates for the purposes set out in this Privacy Policy.

10. Length of time personal information is kept for

We will not keep your personal information for longer than is required for the purposes for which the information was collected under this Policy.  In some cases, we may need to keep your personal information for longer in order to meet legal requirements.

11. Use of ‘cookies’

A cookie is a piece of programming (that may also hold your personal information) which enables us to customise services on our website and may be used for remarketing purposes. For example, a cookie can be used to store registration information so that you do not need to re-enter that information on a subsequent visit to the site. We may send cookies to your computer while you are accessing our website. We may also collect non-attributed (anonymous) information regarding your use of our website. Our use of cookies helps us to provide you with a better experience during your use of our website by allowing us to understand what areas of the site, or particular services, are of interest to you. Some web browsers enable you to decline the receipt of cookies. If you utilise this function you will still be able to access this site albeit without some enhancement features.

12. Links to Other Websites

Our website may contain links to other sites that are not under our control. We have no responsibility for linked websites and provide them solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or warranties about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

13. Accessing your personal information

You have rights under the Act to access and request the correction or amendment of any personal information we hold about you. You can exercise these rights by emailing us at PrivacyOfficer@armstrongs.co.nz.  Please provide your name and address and provide brief details of what information you want (this helps us to more readily locate your data). In some cases, there may be a charge for providing copies of your personal information to you. If so, we will advise you of this prior to sending your information to you.

14. Policy Changes

We may review this Policy from time to time.  For customers, any changes will be notified by posting an updated version on our website. Your use of our website following any updates constitutes acceptance of this Policy as amended. We recommend you regularly review the Policy when you visit our website. If you do not agree with any aspect of the updated Policy, you must promptly notify us and cease using our services.

Who you can contact for further information?
If you have any queries about this Privacy Policy or personal data we have collected please contact our Privacy Officer at:

Email address: PrivacyOfficer@armstrongs.co.nz

Address: 61 Mountain Road, Mt Wellington, Auckland, 1072