Privacy Policy

Barbagallo Group commitment to privacy

• Barbagallo Investments Trust (ACN 008 919 462), its subsidiaries and affiliates in Australia (collectively referred to as ‘Barbagallo Group’) are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws (Privacy Laws).
• Our respect for our customers’ right to privacy of their personal information is paramount. We have policies and procedures to ensure that all personal information, no matter how or where it is obtained, is handled sensitively, securely and in accordance with the Privacy Laws.
• This document sets out our policies for managing your personal information and is referred to as our Privacy Policy, including:
• matters of which you should be aware of regarding information that we may collect about you;
• our policies on the management of personal information; and
• generally, what sort of information we hold, for what purposes, and how we collect, hold, use and disclose that information.
• In this Privacy Policy, “we” and “us” refers to Barbagallo Group and “you” refers to any individual about whom we collect personal information.

About Barbagallo Group

• Barbagallo Group is an Australian organization comprising of a number of divisions, including luxury automotive dealerships and servicing and the supply of luxury watercraft.
• Barbagallo Group offers a range of services and products, including:
  • luxury motor vehicle sales, servicing and parts (including Jaguar, Land Rover, Volvo, Fiat, Alfa Romeo, Infiniti, Audi, Lamborghini, Maserati, Ferrari, Aston Martin, Abarth and Rolls Royce);
  • luxury motor yacht broking (including Rayglass Protector Boats and Sunseeker);
  • chattel finance;
  • Horologist Watches; and
  • Pink Tank Events event planning.
• Please contact us for a full list of the companies which comprise Barbagallo Group and which are subject to this Privacy Policy.

What information does Barbagallo Group collect about you?

• Clients and prospective clients
  • When you enquire about our services or when you become a client of Barbagallo Group, a record is made which includes your personal information.
  • The types of personal information that we may collect vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:
    • your name, e-mail, postal address and other contact details;
    • information about your employer or an organisation who you represent;
    • your professional details; and
    • any additional personal information you provide to us, or authorise us to collect, as part of your interaction with Barbagallo Group.
• Prospective employees or applicants
  • We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.
  • We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions.
• Other individuals
  • Barbagallo Group may collect personal information about other individuals who are not clients of Barbagallo Group. This includes customers and members of the public who participate in events we are involved with, individual service providers and contractors to Barbagallo Group, and other individuals who interact with Barbagallo Group on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with Barbagallo Group. Generally, it would include information such as your name, contact details, and information regarding our interactions and transactions with you.
  • If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
  • In limited circumstances, Barbagallo Group may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by Barbagallo Group we may collect health information about you in an emergency or otherwise with your consent.
  • We may collect personal information about children (for example, when children participate in events we are involved with). Where children do not have sufficient maturity and understanding to make decisions about their personal information, we will require their parents or guardians to make decisions on their behalf.
  • You can always decline to give Barbagallo Group any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.
• Visitors to our websites
  • The way in which we handle the personal information of visitors to our websites is discussed below.

How and why does Barbagallo Group collect and use your personal information?

• Barbagallo Group collects personal information reasonably necessary to carry out our business, to assess and manage our clients’ needs, and provide services, for example, in relation to automotive sales and servicing, sourcing a request by you to locate a motor vehicle, booking a service or purchasing a motor vehicle part. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you or third parties and managing client relationships.
• The purposes for which Barbagallo Group usually collects and uses personal information depends on the nature of your interaction with us, but may include:
  • responding to requests for information and other general inquiries;
  • managing, planning, advertising and administering programs, events, competitions and performances;
  • researching, developing and expanding our facilities and services;
  • informing you of our activities, events, facilities and services;
  • recruitment processes (including for volunteers, internships and work experience); and
  • responding to enquires and complaints.
• Barbagallo Group generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:
  • our affiliated and related companies; and
  •  third party suppliers and contractors who assist us to operate our business.
  • Barbagallo Group also collects and uses personal information for market research purposes and to improve our delivery of products and services.

How does Barbagallo Group interact with you via the internet?

• You may visit our websites (for example: www.barbagallo.com.au) without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to Barbagallo Group will be managed in accordance with this Privacy Policy.
• Barbagallo Group’s websites use cookies. A “cookie” is a small file stored on your computer’s browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites and information regarding collective age, gender and interest demographics to Barbagallo Group. You are not identifiable from such information.
• You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.
• Barbagallo Group’s websites may contain links to third-party websites. Barbagallo Group is not responsible for the content or privacy practices of websites that are linked to our website.

Can you deal with Barbagallo Group anonymously?

• Barbagallo Group will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for Barbagallo Group to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

How does Barbagallo Group hold information?

• Barbagallo Group stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third party storage providers based in Australia and overseas). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
• Barbagallo Group maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
• Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.
• We take steps to destroy or de-identify information that we no longer require.

Does Barbagallo Group use or disclose your personal information for direct marketing?

• Barbagallo Group may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.
• If you opt-out of receiving marketing material from us, Barbagallo Group may still contact you in relation to its ongoing relationship with you.

How does Barbagallo Group use and disclose personal information?

• For clients
  • The purposes for which we may use and disclose your personal information will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may disclose information about you to service providers where this is relevant to our services.
• For customers and participants
  • If you are a customer or participant in an event, we may disclose your personal information to our clients and venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur.
• Disclosure to contractors and other service providers
  • Barbagallo Group may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.
• Personal information may also be shared between related and affiliated companies of Barbagallo Group, located in Australia and overseas.
• Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
• Use and disclosure for administration and management
• Barbagallo Group may also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
  • administering billing and payments and debt recovery;
  • planning, managing, monitoring and evaluating our services;
  • quality improvement activities;
  • statistical analysis and reporting;
  • raining staff, contractors and other workers;
  • risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
  • responding to enquiries and complaints regarding our services;
  • obtaining advice from consultants and other professional advisers; and
  • responding to subpoenas and other legal orders and obligations.
  • (Other uses and disclosures
• We may use and disclose your personal information for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.

Does Barbagallo Group disclose your personal information overseas?

• Barbagallo Group is an Australian organisation and works with clients, service providers, sponsors and commercial interests predominantly in Australia but also overseas. Your personal information may be disclosed to overseas recipients.
• Unless we have your consent, or an exception under the Australian Privacy Principles applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.
• Entities which are related entities of Barbagallo Group or are otherwise affiliated with Barbagallo Group, have operations in overseas countries. In circumstances where your information is disclosed to overseas recipients, those recipients are likely to be located in countries in the regions in which Barbagallo Group and its related entities and affiliates operate.

How can you access or seek correction of your personal information?

• You are entitled to access your personal information held by Barbagallo Group on request. To request access to your personal information please contact our Customer Relations Manager using the contact details set out below.
• You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
• We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
• However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
• We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

What should you do if you have a complaint about the handling of your personal information?

• You may contact Barbagallo Group at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.
• You may make a complaint about privacy to the Customer Relations Manager at the contact details set out below.
• The Customer Relations Manager will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
• If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents, and speak with individuals involved.
• In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
• If you are not satisfied with our response to your complaint, or you consider that Barbagallo Group may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

How changes are made to this Privacy Policy?

• Barbagallo Group may amend this Privacy Policy from time to time, with or without notice to you. An updated version of this Privacy Policy will be maintained on our website so that you have an understanding of the data we collect, how we use it, and under what circumstances we disclose it. We recommend that you visit our website regularly to keep up to date with any changes.
• Barbagallo Group is committed to responsible privacy practices and to complying with the National Privacy Principles contained in the Privacy Act (Cth). Except where the information which Barbagallo Group holds is exempt under the Privacy Act (such as employee information contained in Barbagallo Group’s employment records) individuals may access the personal information which Barbagallo Group holds about them.
• Generally, Barbagallo Group holds personal information about its customers for the purposes of notifying them about field service action, for example recalls and scheduled servicing, and for customers to obtain warranties or requested additional services from Barbagallo Group.

How can you contact Barbagallo Group?

• The contact details for Barbagallo Group are:
• Custodia Di Trento
• Barbagallo Group Customer Relations Manager
• 352-362 Scarborough Beach Road, Osborne Park WA 6017
• custodia@barbagallo.com.au
• (08) 9231 5999
• This Privacy Policy was last updated on 17 September 2020.