Workshop Privacy & Vehicle Recording Policy

ASLmods – Workshop Privacy & Vehicle Recording Policy

1. About this Policy

ASLmods (WA) ABN 26 693 324 275 (ASLmods, we, us or our) respects the privacy of its customers and is committed to handling personal information responsibly.

This Workshop Privacy & Vehicle Recording Policy explains how ASLmods collects, holds, uses and discloses personal information in connection with its Workshop Services.

It applies to customers, vehicle owners and other individuals whose personal information is provided to ASLmods in connection with Workshop Services.

This Policy should be read together with the:

• ASLmods Workshop Terms & Conditions;
• ASLmods Workshop Warranty Policy;
• ASLmods Workshop Cancellation, Deposits & Refunds Policy;
• applicable Quote or Estimate;
• applicable Work Order; and
• applicable Work Authorisation.

Where applicable, ASLmods handles personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

2. Personal Information We May Collect

In connection with Workshop Services, ASLmods may collect and hold information including:

2.1 Customer Information

• name;
• residential or postal address;
• email address;
• telephone number;
• billing information;
• payment information;
• invoice and transaction information;
• correspondence and communications with ASLmods;
• booking information;
• warranty and complaint information; and
• other information reasonably required to provide Workshop Services.

2.2 Vehicle Information

ASLmods may collect information concerning the Customer's Vehicle, including:

• registration number;
• Vehicle Identification Number (VIN);
• make, model and year;
• engine number or identification;
• odometer reading;
• engine and drivetrain configuration;
• modifications;
• accessories;
• service and repair history provided to ASLmods;
• previous workshop information where supplied;
• diagnostic information;
• fault codes;
• ECU information;
• tuning information;
• calibration information;
• Vehicle configuration;
• performance information;
• photographs and videos;
• condition reports; and
• other technical information reasonably required to perform Workshop Services.

Some Vehicle information may constitute personal information where it identifies, or can reasonably identify, an individual.

3. How We Collect Information

ASLmods may collect personal information:

• directly from the Customer;
• through workshop enquiries;
• when a Quote or Estimate is requested;
• when a Workshop booking is made;
• through telephone, email, SMS or electronic communications;
• when the Vehicle is delivered to ASLmods;
• while inspecting, diagnosing, dismantling, repairing, modifying or testing the Vehicle;
• through diagnostic equipment or software;
• from photographs or video recordings;
• during road testing;
• through warranty claims;
• through invoices and payment records;
• from a person authorised by the Customer;
• from manufacturers, suppliers or subcontractors where reasonably necessary; and
• from other lawful sources where reasonably necessary for the Workshop Services.

Where practicable, ASLmods will collect personal information directly from the individual concerned.

4. Why ASLmods Collects Personal Information

ASLmods may collect, hold and use personal information for purposes including:

• providing Quotes and Estimates;
• making and managing Workshop bookings;
• identifying the Customer and Vehicle;
• performing Workshop Services;
• ordering and supplying parts;
• diagnosing Vehicle faults;
• determining Vehicle compatibility;
• carrying out engine conversions and modifications;
• programming, configuring or tuning Vehicle systems;
• road testing and commissioning;
• maintaining workshop and service records;
• contacting the Customer about their Vehicle;
• obtaining approval for additional work;
• processing payments and invoices;
• managing deposits and progress payments;
• administering warranties;
• investigating warranty claims;
• handling complaints and disputes;
• maintaining evidence of Vehicle condition;
• managing safety and risk;
• dealing with manufacturers and suppliers;
• complying with legal, taxation, insurance and regulatory obligations;
• preventing or investigating fraud or unlawful activity; and
• other purposes reasonably connected with ASLmods' Workshop Services.

5. Vehicle Photographs and Videos

ASLmods may photograph or video a Vehicle before, during and after Workshop Services.

These recordings may be made for purposes including:

• documenting the Vehicle's condition when received;
• recording existing damage;
• documenting dismantling;
• recording component condition;
• diagnosis and fault finding;
• documenting work performed;
• recording fabrication or installation;
• technical reference;
• quality control;
• warranty assessment;
• communicating with the Customer;
• communicating with manufacturers or suppliers;
• insurance or dispute purposes;
• staff training; and
• maintaining workshop records.

Photographs or videos taken for these purposes may form part of ASLmods' records relating to the Vehicle and Workshop Services.

6. Marketing and Social Media

ASLmods may photograph or record Workshop Services, engine conversions, fabrication work, completed builds and Customer Vehicles for use in:

• ASLmods' website;
• social media;
• advertising and promotional material;
• educational or technical content;
• project showcases; and
• other ASLmods marketing activities.

Unless the Customer opts out in accordance with section 7, the Customer authorises ASLmods to use photographs and recordings of their Vehicle and the Workshop Services performed for these purposes.

When photographs or recordings are used for marketing or social media:

• Vehicle registration plates will be covered, obscured or otherwise made unreadable;
• the Customer's name will not be published or disclosed unless the Customer specifically requests or authorises ASLmods to do so;
• personal documents, addresses, telephone numbers and other unrelated personal information will not intentionally be displayed; and
• ASLmods will take reasonable steps to avoid publishing other information that directly identifies the Customer.

The Customer acknowledges that their Vehicle may still be recognisable to the Customer or to persons already familiar with the Vehicle due to its appearance, modifications, features or other characteristics.

7. Marketing and Social Media Opt-Out

Customers may opt out of having their Vehicle used in ASLmods marketing or social-media content.

A Customer who does not want their Vehicle photographed or recorded for marketing purposes must notify ASLmods, preferably in writing, before or during the Workshop Services and before the relevant content is published.

ASLmods will take reasonable steps to record and comply with the Customer's opt-out request.

Where a Customer has not opted out, ASLmods may use photographs or recordings of the Vehicle and work performed for the purposes described in section 6, subject to the privacy protections contained in that section.

An opt-out from marketing or social-media use does not prevent ASLmods from taking or retaining photographs, videos or other records reasonably required for:

• documenting the Vehicle's condition;
• Workshop Services;
• diagnosis and fault finding;
• quality control;
• technical records;
• warranty assessment;
• insurance;
• safety;
• legal or regulatory requirements; or
• dispute resolution.

Such operational records will not be used for marketing or social-media purposes where the Customer has opted out.

8. Customer Images and Content

If a Customer voluntarily supplies ASLmods with photographs, videos, reviews, testimonials or other content, ASLmods may retain that material as part of its records.

ASLmods will obtain any permission reasonably required before using identifiable Customer-provided content for advertising or promotional purposes.

9. Diagnostic and Vehicle Data

During Workshop Services, ASLmods may access, collect or record technical data stored in or generated by the Vehicle.

This may include:

• diagnostic trouble codes;
• ECU information;
• ECU files;
• software versions;
• calibration information;
• tuning information;
• sensor data;
• operating data;
• temperatures;
• pressures;
• boost information;
• fuel-system information;
• electrical information;
• odometer information; and
• other technical Vehicle data.

ASLmods may use this information for diagnosis, repair, modification, tuning, testing, commissioning, warranty assessment and technical records.

10. ECU Files, Tuning Files and Calibration Data

Where ASLmods reads, creates, modifies or receives ECU files, tuning files, calibration data or similar technical information, ASLmods may retain copies for:

• workshop records;
• future diagnosis;
• restoration or adjustment;
• warranty assessment;
• technical reference; and
• providing future Workshop Services.

This information may also contain proprietary or confidential technical information belonging to ASLmods or a third-party tuning or software provider.

Nothing in this Privacy Policy transfers ownership of intellectual property contained in a tuning file, calibration or other technical work.

11. Dashcams and In-Vehicle Recording Devices

Vehicles delivered to ASLmods may contain:

• dashcams;
• cabin cameras;
• audio recording devices;
• GPS tracking systems;
• telematics;
• security cameras; or
• other monitoring or recording devices.

To protect employee privacy, workshop confidentiality, Customer privacy, safety and ASLmods' legitimate business interests, ASLmods may disconnect, disable, cover or otherwise prevent recording by such devices while the Vehicle is:

• inside the workshop;
• being worked on;
• being moved;
• undergoing diagnosis;
• undergoing testing; or
• being road tested.

ASLmods will not intentionally access private recordings stored on Customer devices unless reasonably necessary and authorised or permitted by law.

12. Personal Property Inside Vehicles

Customers should remove:

• personal documents;
• financial information;
• electronic devices;
• valuables; and
• other sensitive personal items

from the Vehicle before leaving it with ASLmods.

During Workshop Services, ASLmods employees or contractors may necessarily encounter personal items or information located inside the Vehicle.

ASLmods will not intentionally access or use such information unless reasonably necessary to perform the Workshop Services, protect property or safety, or where otherwise authorised or required by law.

13. Disclosure of Information

ASLmods may disclose personal or Vehicle information where reasonably necessary to:

• employees and authorised personnel;
• subcontractors;
• parts suppliers;
• manufacturers;
• machinists;
• fabricators;
• automotive electricians;
• tuners;
• engineers;
• diagnostic specialists;
• freight and transport providers;
• insurers;
• professional advisers;
• IT, software and cloud-service providers;
• payment and accounting providers;
• government authorities;
• law-enforcement agencies; or
• other persons where authorised or required by law.

ASLmods will only disclose information reasonably necessary for the relevant purpose.

14. Manufacturers and Warranty Providers

Where a warranty, technical or diagnostic issue involves a third-party component, ASLmods may provide relevant information to the:

• manufacturer;
• Australian distributor;
• supplier;
• warranty provider; or
• technical representative.

Information disclosed may include Vehicle information, photographs, videos, diagnostic results, invoices and details of the alleged failure where reasonably necessary to assess or administer the matter.

15. Overseas Disclosure and Cloud Services

Some service providers, software platforms, manufacturers, suppliers or cloud-storage providers used by ASLmods may store or process information outside Australia.

Where the Privacy Act applies, ASLmods will manage overseas disclosures in accordance with applicable privacy requirements.

Where practicable and required, ASLmods will identify the countries in which overseas recipients are likely to be located.

16. Storage and Security

ASLmods may hold personal information in:

• electronic business systems;
• accounting systems;
• workshop records;
• email systems;
• cloud-storage services;
• diagnostic systems;
• Customer files; and
• physical records where applicable.

ASLmods takes reasonable steps to protect personal information from:

• misuse;
• interference;
• loss;
• unauthorised access;
• unauthorised modification; and
• unauthorised disclosure.

ASLmods may retain records for as long as reasonably required for the purpose for which they were collected, for warranty and technical purposes, or as required by applicable law.

When information is no longer required to be retained, ASLmods will take reasonable steps to destroy or de-identify it where required by law.

17. Workshop and Vehicle Records

ASLmods may retain records relating to Workshop Services after the Vehicle has been collected or sold.

These records may include:

• Quotes;
• Work Orders;
• invoices;
• Vehicle identification information;
• photographs;
• videos;
• diagnostic records;
• ECU or tuning information;
• parts information;
• work performed;
• Customer authorisations;
• warranty records; and
• communications.

These records may be retained where reasonably necessary for business, taxation, technical, warranty, insurance, dispute-resolution or legal purposes.

18. Accessing and Correcting Personal Information

A person may request access to personal information ASLmods holds about them or request that inaccurate, incomplete or out-of-date personal information be corrected.

Requests should be made using the contact details in section 23.

ASLmods may require reasonable evidence of identity before providing access to or correcting personal information.

ASLmods will respond to requests in accordance with applicable privacy law.

19. Anonymity and Pseudonyms

Where practicable, a person may make a general enquiry to ASLmods without identifying themselves or by using a pseudonym.

However, ASLmods will generally require accurate identifying and contact information where necessary to:

• make a Workshop booking;
• identify a Vehicle;
• provide a Quote;
• perform Workshop Services;
• issue invoices;
• process payments;
• administer warranties; or
• meet legal or regulatory requirements.

20. Direct Marketing

ASLmods may use Customer contact information to communicate about:

• existing Workshop Services;
• Vehicle servicing;
• warranty matters;
• follow-up inspections;
• products or services that may be relevant to the Customer; and
• ASLmods promotions or marketing,

where permitted by law.

Where required, Customers will be provided with a reasonable means of opting out of direct marketing communications.

An opt-out from marketing communications does not prevent ASLmods from sending communications reasonably necessary in connection with an existing booking, Workshop Service, invoice, safety matter or warranty claim.

21. Privacy Complaints

If a person believes ASLmods has mishandled their personal information, they may submit a privacy complaint using the contact details in section 23.

The complaint should provide sufficient information for ASLmods to understand and investigate the concern.

ASLmods will review the complaint and respond within a reasonable period.

If the individual is not satisfied with ASLmods' response and the Privacy Act applies, they may be entitled to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

22. Australian Privacy Principles

Where ASLmods is subject to the Privacy Act 1988 (Cth), it will handle personal information in accordance with applicable Australian Privacy Principles.

Nothing in this Policy is intended to reduce any privacy right that an individual has under applicable law.

23. Contact Details

Privacy enquiries, access requests, correction requests, complaints and other questions relating to this Policy may be directed to:

ASLmods
ABN: 26 693 324 275
Address: 20 Thurso Rd, Myaree WA 6154
Phone: 0477 313 106
Email: admin@aslmods.com

24. Changes to this Policy

ASLmods may update this Workshop Privacy & Vehicle Recording Policy from time to time where its Workshop Services, technology, information-handling practices or legal obligations change.

The current version will be made available through the ASLmods website.

Unless otherwise required by law, amendments will apply from the date the updated Policy is published.