Priorm Digital Marketing Limited (“we, us, our”) comply with the New Zealand Privacy Act 2020 when dealing with personal information. It applies to all personal information that we collect, process, or receive. This may be in person or via www.priorm.co.nz we maintain (“the Website”), email, social media, apps, over the phone, or through other channels.
Personal information is information about an identifiable individual (a natural person), and includes personal data, personally identifiable information and equivalent information under applicable privacy and data protection laws.
This policy does not limit or exclude any of your rights under the New Zealand Privacy Act 2020. For further information on the New Zealand Privacy Act 2020, see www.privacy.org.nz.
This policy was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed. Any request for further information should be sent to email@example.com.
CHANGES TO THIS POLICY
We may change this policy by uploading a revised policy onto our Website. The change will apply from the date that we upload the revised policy.
This policy was last updated on 22nd March 2021.
Where we collect personal information from or about children aged under 16 for the purposes of providing our services, we rely on representations from customers that they have appropriate individual or parental consent for any such children.
WHAT PERSONAL INFORMATION DO WE COLLECT
We will collect your personal information where you choose to provide it. The type of personal information we collect depends on the nature of our relationship with you.
When you fill in a contact or enquiry form on our Website, call us, meet us in person or otherwise contact us, we collect your name, email address, phone number and any other information you choose to provide to us.
When you sign up to our newsletter and other electronic alerts, we collect your name, email address, phone number, user preferences and any other information you provide to us when you ask to receive our newsletter or other alerts. You can unsubscribe from them at any time.
When you respond to our feedback surveys, we collect your name, email address, date of birth, demographic information and any other information you choose to include in your response.
When you purchase services from us, we may collect your name, date of birth, email address, phone number, credit card information, and any other information you submit to us for billing and order fulfilment purposes.
Some of the personal information that we collect directly from you may be mandatory and some may be optional. We will let you know which of these applies at the time we collect the relevant personal information. While you do not have to provide us with some of the information that we may request, this might mean that our services may not perform as well as they should, or that we may not be able to provide some parts of the website or all of our services to you. If you require further information about the consequences of not providing us with any information, please contact us at firstname.lastname@example.org.
When you access and use our Website or related services we may automatically collect information about your device and usage of our Website, products and services, including your IP address, operating system, browser type, time spent on certain pages of the website, pages visited, links clicked and language preferences.
We deliver some email updates via independent mail management company Mailchimp.
Mailchimp provides analytics to us on how people interact with our newsletters (eg, how many subscribers have opened emails or clicked on links). This means that we and Mailchimp will be able to see your name, email address and details about which links in our newsletters you have clicked on. We only use this information to assess newsletter effectiveness.
For more information, see the Mailchimp terms and conditions.
HOW WE USE YOUR PERSONAL INFORMATION
We may use your personal information to:
- verify your identity
- provide our Website, products and services to you
- provide you with documentation
- market our products and services to you, including contacting you electronically (e.g. by text or email for this purpose)
- improve our Website, products and services
- publish things on our Website (e.g. comments on pages)
- run promotions (e.g. referral and loyalty programmes, surveys and contests)
- bill you and collect money that you owe us, including authorising and processing credit card transactions
- respond to communications from you, including enquiries and complaints
- conduct research and statistical analysis
- tailor content or advertisements on our Website
- protect and/or enforce our legal rights and interests, including defending any claim
- respond to lawful requests by public authorities, including to comply with law enforcement requirements, or
- for any other purpose authorised by you or applicable law.
We may transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.
DISCLOSING YOUR PERSONAL INFORMATION
We may disclose your personal information to:
- any business that supports (or delivers services you have requested in connection with) our website, products and services, including any person that hosts or maintains any underlying IT system or data centre that we use to provide our Website, products or services or that we use to process payments
- a credit reference agency for the purpose of credit checking you
- third parties (for anonymised statistical information)
- professional advisers e.g. accountants, lawyers or auditors
- a person who can require us to supply your personal information (e.g. a law enforcement agency or regulatory authority)
- any other person with your consent
- any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition
- any other person authorised by applicable law.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
A business that supports our Website, products and services or delivers services that we sell as agent may be located outside of New Zealand (the country where we are incorporated) and also outside of the country where you are located. This means that the personal information we collect may be transferred to, and stored in, a country outside of New Zealand and the country where you are located. Therefore we cannot guarantee that the same standards apply in that country as apply in New Zealand. By proceeding to give us your personal information, you acknowledge and consent to this arrangement.
For further information, please contact us at email@example.com.
Some of the personal information we collect is processed in New Zealand. New Zealand is recognised by the European Commission as a country that has an adequate level of data protection and we may rely on this decision in transferring personal information to New Zealand.
PROTECTING YOUR PERSONAL INFORMATION
As required by applicable law, we will take steps to keep your personal information safe from loss, unauthorised activity, or other misuse. You play an important role in keeping your personal information secure by maintaining the confidentiality of any password and accounts used in relation to our products and services. You should not disclose any such password to third parties. Please notify us immediately if there is any unauthorised use of your account or any other breach of security.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
Subject to certain grounds for refusal under applicable law, you have the right to access your personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.
Where you request a correction, if we think the correction is reasonable and we are reasonably able to change your personal information, we will make the correction. In all other cases, we will take reasonable steps to make a note of the personal information that was the subject of your correction request.
If you want to exercise either of the above rights, email us at firstname.lastname@example.org.
Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information to be corrected and the correction that you are requesting).
Subject to applicable law, we may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.
While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.
DATA RETENTION POLICY
The personal information that we collect and use is not intended to be kept longer than necessary for the purposes for which it is collected. Generally, we will keep personal information we collect for no longer than six months unless the law requires that we keep it for longer.
LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION
Our lawful basis for processing your personal information that we collect, use and disclose depends on the personal information collected and the context in which we collect it.
Generally, we collect personal information from you where we have your consent, where processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, or where processing is necessary for the purposes of our legitimate interests (except where such interests are overridden by your interests or fundamental rights and freedoms).
Where we process personal information based on your consent, you may withdraw your consent at any time.
Despite the above, we may process your personal information where such processing is necessary for compliance with applicable laws.
If you have any question about the legal basis on which we process personal information or need further information, please contact us at email@example.com.
Your rights in relation to your personal information include:
- right of access – if you ask us, we will confirm whether we are processing your personal information and provide you with a copy of that personal information.
- right to rectification – if the personal information we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed. We will take reasonable steps to ensure inaccurate personal information is rectified. If we have shared your personal information with any third party, we will tell them about the rectification where possible.
- right to erasure – when your personal information is no longer needed for the purposes for which you provided it, we will delete it. You may request that we delete your personal information and we will do so if deletion does not contravene any applicable law. If we have shared your personal data with any third party, we will take reasonable steps to inform those third parties that they must delete your personal information.
- right to withdraw consent – if the basis of our processing of your personal information is consent, you can withdraw that consent at any time.
- right to restrict processing – you may request that we restrict or block the processing of your personal information in certain circumstances. If we have shared your personal information with any third party, we will tell them about this request where possible.
- right to object to processing – you may request that we stop processing your personal information at any time and we will do so to the extent required by applicable law.
- rights related to automated decision-making, including profiling – you have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such automated decision-making is necessary for entering into, or the performance of, a contract with you, is authorised by applicable laws or is based on your explicit consent. We do not undertake automated individual decision-making.
- right to data portability – you may obtain your personal information from us that you have consented to give us or that is necessary to perform a contract with you. We will provide this personal information in a commonly used, machine-readable and interoperable format to enable data portability to another data controller. Where technically feasible, and at your request, we will transmit your personal information directly to another data controller.
- the right to complain to a supervisory authority – you can report any concern you have about our privacy practices to your local data protection authority.
Where personal information is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.
If you would like to exercise any of your above rights, please contact us at firstname.lastname@example.org. If you are not satisfied by the way we deal with your query, you may refer your query to your local data protection authority.