the way in which we collect, hold, use and disclose your personal information; and
your rights in relation to your personal information.
Personal information is information or an opinion about an identified, or reasonably identifiable, individual.
All personal information collected by Zilch is handled in compliance with the New Zealand Privacy Act 1993 (Privacy Act), including the 12 New Zealand Privacy Principles.
WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?
We may collect your personal information (whether directly from you or through a third party) when you:
· or your organisation, use our services or apply to use our services;
· or your organisation, provide services to us or offer to provide services to us;
· are a driver of one of our vehicles, during your use of such vehicle;
· apply for employment with us or during your employment with us;
· contact us for any reason including, but not limited to, reporting a problem with one of our services or websites, requesting further services or otherwise seeking our assistance;
· register or log in to use one of our websites, Zilch App, social media pages or social media profiles (Websites);
· post or contribute material on our Websites; or
· subscribe to receive information or updates from us, fill in surveys or research, or participate in promotions or competitions we offer.
While we will always aim to collect your personal information directly from you, there may be occasions when Zilch collects your personal information from other sources, such as from:
· a public or commercial information services provider, for example when undertaking a credit check or verifying driver’s licence details;
· a third party assisting us to locate or communicate with you, for example your employer or an IT services provider;
· vehicle dealers and other businesses involved in dealings with both you and us, for example an insurance company in the event of an accident; or
· a current or previous employer or an educational institution, when you are applying for employment with us.
WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?
The kinds of personal information Zilch collects varies according to our relationship with you and includes:
· contact and identification information, such as your name, address, email address, telephone number and date of birth;
· Zilch account balances, Zilch account activities and payment history and transactions with us or third parties, for example credit card companies;
· government identifiers and related information, such as your driver’s licence, which we may obtain to verify your identity or eligibility at the time you request a service from us;
· other details relating to your dealings with Zilch, for example, information about agreements or other arrangements or transactions you may have with us;
· trip and vehicle driving statistics while using one of our vehicles, which may include details of where, when and how fast you have driven and any incidents or undesirable driver behaviours (for example hard acceleration or hard braking);
· any information you voluntarily provide to us; and
· any other information lawfully obtainable under the Privacy Act.
We occasionally collect information through our Websites using cookies and similar technologies, including Google Analytics, in order to help us understand how people use our Websites. For example, Google Analytics may provide us with information on how many people visit our Websites and what pages they visit. We use the information provided by Google Analytics to help us improve our Websites. The information we collect through our Websites is aggregated and does not identify you personally.
You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of our Websites. In addition, you can choose to opt out of Google Analytics across all websites you visit without impacting your ability to access our site. You can find out more information on how to opt out of Google Analytics here.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
WHAT IF YOU DON’T PROVIDE US WITH PERSONAL INFORMATION?
Whilst you are under no obligation to provide your personal information to us, without certain information from you we may not be able to provide you with our services or otherwise fulfil the purpose for which we have requested the information
HOW WE USE YOUR PERSONAL INFORMATION
We may use your personal information for one or more of the following purposes:
(a) To fulfil a contract, or take steps related to a contract, with you or your organisation including to provide you with a vehicle;
(b) As required by us to pursue our legitimate interests, including:
· managing our products and services;
· managing our relationship and arrangements with you or your organisation;
· accounting, billing and other internal administrative purposes;
· assessing, processing and investigating insurance risks or claims;
· enforcing our rights, including undertaking debt collection activities and legal proceedings; and
· undertaking business funding and development activities;
(c) where required by law, including to comply with our record-keeping obligations;
(d) to carry out surveys into your experience of our products and services;
(e) to inform you of products and services that may be of interest; and
(f) to notify you about changes to our products and services.
DISCLOSURE OF YOUR PERSONAL INFORMATION
We will only disclose your personal information to other parties when we are legally permitted to do so. When we disclose personal information to others, we always do so under contractual and security arrangements designed to protect your personal information and to comply with applicable privacy requirements.
We may share your personal information with:
· any of our group companies on a confidential basis;
· our business partners, suppliers and sub-contractors in relation to any services we provide to you or any other dealings we have with you in the normal course of business;
· our financial and other professional advisors;
· our data processing and IT service providers;
· regulatory bodies and law enforcement authorities;
· other participants in financial and payment systems who have a relationship with you, such as banks, credit providers and credit agencies, or who have a relationship with us, such as debt collectors;
· your employer if you are a driver of our vehicles through a business membership or if you work for an organisation with whom we interact, however we will not share with your employer any personal information we have only as a result of you separately being a customer of ours in a personal capacity;
· your guarantors and security providers, where relevant; and
· a buyer or prospective buyer of us or any part of our business or assets.
WHERE WE STORE YOUR INFORMATION
We may store your personal information on computers located in New Zealand, Vietnam, Australia, America and in various other locations from time to time. We might disclose your personal information overseas for a variety of reasons including for the purposes described above and to the recipients described above in accordance with applicable privacy laws relating to the transfer of that personal information to foreign countries. You agree and acknowledge that the overseas recipient will be subject to the privacy law of their local jurisdiction.
We will only use and disclose your personal information for marketing purposes:
(a) within the Zilch Group of Companies; and
(b) where you have consented to receive such marketing.
We do not and will not sell your personal information to third parties for direct marketing purposes.
SECURITY AND RETENTION OF YOUR PERSONAL INFORMATION
We may hold your personal information in physical form or in electronic form on our systems or the systems of our IT and data processing service providers. We take reasonable steps to ensure that the personal information we hold is protected from misuse, interference, loss and from unauthorised access, modification or disclosure.
We will destroy or de-identify personal information in circumstances where it is no longer required to fulfil the purpose we collected it for, including as may be required for any record keeping, legal or accounting purposes.
Personal information may be kept for longer periods where required by applicable law or regulation or in order to establish, exercise or defend our legal rights.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
You have certain rights in respect of our use of your personal information:
· right of access: in general, you have the right to obtain confirmation from us as to whether we process personal information about you and access a copy of such personal information.
· right to rectification: you have the right to request inaccurate personal information we hold about you is rectified and incomplete personal information is completed.
If at any time you would like to exercise any of the rights set out above, or you would like more information on our approach to privacy, please contact our Privacy Officer at firstname.lastname@example.org.
Please note that, in order to obtain access to your personal information, you will have to provide proof of identity. This is necessary to ensure that personal information is provided only to the correct individual and that your privacy and the privacy of others is protected.
Where you request access to your personal information, we would be grateful if you are reasonably specific about the information you require.
COMPLAINTS AND DISPUTES
We hope you won’t need to, but if you wish to make a complaint about our handling of your personal information, please contact our Privacy Officer at email@example.com.
Following a complaint, our Privacy Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation.
At all times, privacy complaints:
will be treated seriously;
will be dealt with promptly;
will be dealt with in a confidential manner; and
will not affect your existing obligations or impact on the commercial arrangements between you and us.
If we do not resolve your complaint to your satisfaction, you have the right to complain to the New Zealand Privacy Commissioner (http://www.privacy.org.nz/your-rights/complaint-form).
HOW TO CONTACT US
Please direct all privacy queries and complaints addressed to our Privacy Officer at firstname.lastname@example.org