The Euro City Group Limited group of companies, including its suppliers, trading as Euro City Limited (collectively referred to as "Euro City", “our”, “us” or "we") is committed to protecting the privacy of the personal information of our current, former and potential customers (referred to as “customers”, “you” and “your”).
If we are unable to collect sufficient personal information, we may not be able to provide you with the full benefit of our products, services and offers or our online and digital platforms.
2. What types of personal information do we collect?
We only collect and process personal information that we consider necessary for the effective functioning or activities of our business. Generally, the types of personal information that we collect from or about you depends on the circumstances in which the information is collected. We have described below examples of the types of personal information that may be collected, however this is not an exhaustive list:
- The main type of personal information that we collect is your name and contact details, including physical and postal address, email addresses, phone numbers, and mobile numbers.
- We will collect your driver’s licence details when you participate in a test drive or when you purchase a vehicle.
- Other personally identifiable information such as demographic information about your age, gender and occupation, as well as information about your hobbies, favourite sports and other interests and preferences may be collected if you choose to provide us with that information, for example when entering a competition or promotion or taking part in a customer experience survey following the purchase or service of your vehicle.
- We may collect your airline membership number for the purpose of facilitating the award of airpoints in relation to your purchase (if applicable);
- We may collect financial and credit information if you are seeking to obtain finance for the purchase of a vehicle, and if you finance your vehicle with European Financial Services, Nelson Building Society, The Money Company, Online Automotive and Finance or any one of our other authorised financial agencies, we may collect information about the finance, such as the amount financed and the type of finance product.
- We will collect information about your vehicle, including its number plate, vehicle identification number (VIN), and service plan schedule.
- We may collect information relating to your dealings with our brands (such as details of vehicle/s purchased, service and repair history, and responses to other questions that we may ask).
- If you request or receive roadside assistance services, we may collect information about where (e.g. location) and when e.g. date, time) you requested roadside assistance services and the assistance service that is required.
- With Digital Data tracking your data may be passed on to third parties for the purposes of our communication and that we may track them digitally to ensure communications are relevant and timely.
- Vehicle connect services require a two-way flow of data to allow full functionality of the system and hence allowing owners to enjoy the full benefits of “Connect”. Should you decide not to allow the vehicles data to be transmitted to Audi AG then we need to be aware of that and secondly, you also need to be aware of the reduced functionality.
- We may collect other types of information you provide us with when making enquiries or providing feedback on our or our Authorised Dealers’ products and services, for example enquiry details, your opinion on products and services, and records of your communications with us.
- We may collect information which you allow to be shared with us that is part of your public profile on a third-party social network, or information you create and share with us by posting it to one of our social networks.
- We may collect information relating to the way you use or navigate any of our websites, customer portals and mobile applications so that we can improve your experience and our communications with you online.
- If you use any of our mobile applications, we may collect information (some of which may be personal information about you), including:
- the number of trips and distances that you have driven;
- the location of your vehicle, including historical locations and past driving history;
- vehicle diagnostic information, such as tyre pressure, amount of fuel in the tank and engine information;
- vehicle driving information, such as speed, braking and acceleration information; and vehicle fuel efficiency;
- mobile phone information such as number, model, operating system and personal location data where you have activated location services on your mobile device; and
- any mobile contact numbers entered in the applications for additional services relating to emergency contacts.
- We may also collect other personal information as otherwise permitted or required by law, as well as any other information that you choose to provide us.
3. How is personal information collected?
We may collect personal information from or about you in a variety of ways. Where possible we will collect personal information directly from you. The most common ways we collect personal information are:
- information you provide us directly either in person, over the phone, by email, or through our digital and online channels, for example:
- if you make an enquiry about any of our vehicle brands, parts, accessories or services, or if you request a test drive, brochure, specification sheet, information or other materials about our vehicles, parts, accessories or services;
- if you interact with us online, including via our websites or through social media channels;
- If you use our customer portal and/or any of our mobile applications;
- if you enter a promotion or competition carried out by Euro City directly or carried out by a third party with official affiliation with or support from Euro City;
- if you participate in a marketing, product development, profiling, survey or market research campaign, including on social media channels; or
- if you request roadside assistance services;
- with vehicle connect
- we may collect personal information from Volkswagen group and its related entities, service providers, contractors, and agents (e.g. if you participate in a customer survey managed by Audi AG, Skoda AG, Volkswagen AG or MG-SAIC Motor Group).
- we may also collect personal information about vehicle owners from the Motor Vehicle Register, in accordance with our authorisation to access this register for specified purposes under section 241 of the Land Transport Act 1998
- we will collect your personal information from the third-party provider of European Financial Services, Nelson Building Society, The Money Company or Online Automotive and Finance amongst others, if you arrange finance for a Euro City vehicle through these services; and
- in certain circumstances we may also collect your personal information from other third parties, including our related entities, service providers, contractors, and agents.
4. For what purposes do we collect, hold, use and disclose personal information?
We only collect, hold, use and disclose personal information for the purposes for which it was originally collected (and for related purposes which you would reasonably expect), unless required or authorised by or under law or if the individual concerned has consented to another use. Some of the specific purposes for which we collect, hold, use and disclose personal information include:
- to enable us to correspond with you and do business together and for reasons related to our business operations, such as to ensure we and our suppliers continue to deliver quality products and services to our customers and potential customers;
- to assist in administering your vehicle purchase, lease, warranty, any extended service plan, roadside assistance, or ongoing vehicle service, and arranging for our suppliers to obtain required vehicles and parts on a timely basis to meet your needs;
- to facilitate your application for finance for the purchase of your vehicle;
- to respond to your enquiries, comments, concerns or requests for information about our vehicles, parts, accessories, services or offers;
- to process sales orders and administer accounts, warranty records and vehicle service records;
- to provide you with necessary support;
- to attend to or assist in the servicing or repair of your vehicle, including the provision of roadside assistance services and online vehicle service and repair booking facilities;
- for product development, market research, and customer surveys (for example, to obtain your feedback and find out your level of satisfaction with our products and services);
- for marketing and promotional activities, including to contact you directly or through our (or our affiliates’) service providers and research agencies for these purposes;
- to carry out our legal compliance obligations, such as to conduct a product safety recall where necessary or inform you of a customer notification or field service action affecting your vehicle on a national and international front;
- if you use any of our mobile applications to provide you with notifications and information about your vehicle;
- to send you service and Warrant of Fitness reminders;
- to contact you with details of new brands vehicles, products or services, or automotive products offered by other parties, or special offers or promotions that we think may be of interest to you;
- we may use information collected from our websites to enable the features of the websites, to improve the websites by determining which of our products, features and services are most popular, and to personalise the experience of the users of our websites;
- we may also process your personal information for other purposes which are disclosed to you, and to which you consent, whether expressly or by implication by providing us with your personal information with knowledge of how we intend to use it; and
- we may also process your personal information without your consent for purposes that are required or authorised by or under any applicable law, including but not limited to meeting our legal obligations, assisting in the investigation of a breach of an agreement or a law, assisting in law enforcement purposes, and protecting our and our customers’ business interests.
5. Who has access to your personal information?
- our employees, officers, contractors, service providers, agents, and partners (for example, mailing houses, marketing agencies, airline programme partners, market research providers, printers, roadside assistance service providers, insurance providers, financiers, website and data hosting providers, data analytics providers, and other IT suppliers);
- our related or affiliated companies and their respective employees, officers, contractors, service providers and agents (and our related or affiliated companies may disclose the personal information directly to their contractors, service providers and agents);
- Volkswagen Group, Audi Group, Skoda Group and MG-SAIC Motor Group and its affiliated or related companies and its and their respective employees, officers, contractors, service providers, dealers, agents, partners, and licensees (and Audi AG and its affiliated or related companies may disclose the personal information directly to their respective contractors, service providers, dealers, agents, partners, and licensees);
- our accountants, insurers, lawyers, auditors and other professional advisors;
- if your vehicle is provided by your employer as part of a corporate or government fleet policy, we may also disclose certain personal information to your employer;
- any other third parties to whom you direct or permit us to disclose your personal information (e.g. third parties with whom we have directly or indirectly arranged services for your benefit);
- third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
- as otherwise permitted or required by or under any applicable law.
In the unlikely event that we sell a part of or the whole of our business, or we are no longer the authorised importer of European or MG products, our records of personal information may be transferred to the new business owner, new importer, or any of its related or affiliated companies (as the case may be).
We will take reasonable steps to ensure that any third-party to whom we disclose personal information is required to comply with the Act.
6. Disclosure of personal information offshore
Some of the third parties to whom we disclose personal information may be located outside New Zealand. For example, as above, we may disclose personal information to Audi AG, Skoda AG, Volkswagen AG or MG-SAIC Motor Group and its affiliated or related companies and to service providers based offshore. In addition, our websites and systems and those of our group companies may also be based on servers located outside of New Zealand.
If we disclose personal information to third parties based offshore, we will comply with the requirements of the Act that relate to the transfer of personal information offshore.
Our websites use a technology called cookies to record the preferences of visitors and enable us to optimise the design of our websites. A "cookie" is a small data element that a website transfers to your computer for record keeping and experience customisation purposes. The length of time that a user’s computer stores cookies is determined by the user’s browser settings.
The use of "cookies" is an industry standard and helps us monitor the effectiveness of our advertising and how visitors use our websites. During normal website usage our website "cookies" do not store your email address or other personal information about you unless you have given your consent, or if it is essential for technical reasons (i.e. secure login). We use this technology to generate statistics and measure website activity to improve the usefulness of customer visits. Each time you access our websites, our server may deliver certain customised information (such as advertisements) to you based on the data stored in your cookie. Third-party vendors may utilise cookies to collect information about the content you view on our websites, customer portals or mobile applications and use that information to show and/or serve our advertisements on other websites based on a user’s prior visits to our websites and other internet activity. We may also use analytics data supplied by third party vendors to inform and optimise our ad campaigns. We may utilise third party cookies in some parts of our websites.
Some of the tags that are used on our websites include, but are not limited to, container tags (such as Google tag manager), which include retargeting tags and analytics tags. These tags provide us with aggregated knowledge and information on website behaviour and user preferences.
8. Storage and Security
We will take reasonable steps to protect your personal information from misuse, interference, corruption, loss or unauthorised access, modification or disclosure, including through physical, electronic and procedural safeguards. However, to the extent permitted by law, we will not be responsible for and exclude all liability arising in relation to any misuse, interference, corruption, loss or unauthorised access, modification or disclosure of your personal information.
If we provide you with any passwords or other security devices it is important that you keep these secret and confidential and do not allow them to be used by any other person. You should notify us immediately if the security of these devices is breached to prevent the unauthorised disclosure of your personal information.
If we become aware of any breach involving your personal information, we will comply with the requirements of the Act relating to the reporting of privacy breaches.
9. How long do we retain your personal information?
We will keep your personal information for as long as it is required for the purposes for which it was collected, taking into consideration our need to answer queries or resolve problems, provide improved and new services, and comply with legal requirements.
When the personal information that we collect is no longer required or is not required to be retained by law, we destroy, delete or permanently anonymise it.
10. Email and other electronic communications
We are committed to full compliance with the Unsolicited Electronic Messages Act 2007.
By using our websites and other online and digital channels and/or by providing us with your personal information you consent to receiving communications from us or from third parties on our behalf using the contact details you have provided (including, without limitation, via direct mailing, email, SMS, telephone call, and other phone number based messaging) which promote and market our products and services, or the products and services of others, from time to time.
You can opt out of those communications at any stage by contacting us using the contact details set out below at paragraph 11or by utilising the "unsubscribe" facility included on all such communications. Once you have unsubscribed from these communications, we will remove you from the corresponding marketing list as soon as is reasonably practicable.
11. Your rights to access and correct personal information
You may obtain confirmation from us as to whether or not we hold personal information about you. You may also request a copy of the personal information and/or request that corrections or changes are made to it. You can make such requests in relation to your personal information by contacting our Privacy Officer using the details set out below. Please quote your name and address and, if possible, provide brief details of what information you want a copy of (this helps us to more readily locate your information).
We will provide you with access to your personal information unless we are required or authorised to refuse such access by law.
In some cases, there may be a charge associated with retrieving and providing a copy of your personal information to you. If so, we will advise you of this prior to sending your information.
All such enquiries should be directed to:
PO Box 626
Phone: 06 835 8810
At all times we will strive to ensure that your personal information is treated confidentially and in accordance with the Act. However, if you have any questions or complaints about the handling of your personal information, please contact our Privacy Officer in the first instance using the contact details set out in paragraph 11 above and we will do our best to assist.
If you are still not satisfied, you can make a complaint to the Privacy Commissioner. Further details on how to do this are available on the Privacy Commissioner website at www.privacy.org.nz.
13. Links to other websites
15. Privacy Act
Without limiting any terms set out in the Privacy Policies, your personal information may be used for market research, marketing and promotional purposes, including for the purpose of communicating information or offers to you relating to our products and services.
Please tick here if you would prefer not to receive any correspondence other than that related directly to your vehicle. Alternatively, you are welcome to contact us at any time using the contact details set out in this agreement to “opt-out” of receiving further communications.