This policy addresses the following:
- What is considered personal information?
- What personal information do we collect and hold?
- Why do we collect personal information?
- What happens if we are not able to collect personal information?
- How do we collect personal information?
- What may we do with your information?
- Do we use personal information for marketing?
- How do we use mobile?
- How do we disclose personal information?
- How can you access or correct personal information?
- How can you complain about a breach of privacy?
- Will your personal information be disclosed outside of NZ?
- What security measures are in place?
- Credit Card Security
1. WHAT IS CONSIDERED PERSONAL INFORMATION?
Within this policy, ?Personal Information? means the same as it does within the Privacy Act 1993. In general terms, this includes any information that can be used to personally identify you. This may include (but is not limited to) your name, age, gender, address, contact details (including phone numbers and email addresses) and possibly financial information, including your payment information. If the information we collect personally identifies you, or you are reasonably identifiable from it, then the information is considered personal information.
2. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We may collect the following types of personal information:
- Mailing or street address,
- Email address,
- Telephone number;
- Age or birth date,
- Profession, occupation or job title,
- Details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries,
- Any additional information relating to you that you provide to us directly through our websites or indirectly through use of our website or online presence through our representatives or otherwise; and information you provide to us through our customer contact centre or customer surveys, or that is publically available.
Your personal information will be held by Covaflex Ltd, Palmerston North, New Zealand
3. WHY DO WE COLLECT PERSONAL INFORMATION?
Covaflex collects, holds, uses and discloses your personal information for the following purposes:
- To provide products and services to you,
- To provide you with information or advice about existing and new products and services,
- To communicate with you and process your requests,
- To manage and enhance our products and services,
- To personalise and customise your experience,
- To provide you with access to secure areas of our websites,
- To conduct competitions or promotions on behalf of Torpedo7 and selected third parties,
- To verify your identity,
- To provide to third parties if you have authorised us to do so,
- To conduct analysis for our company.
- To conduct business processing functions for operation of our websites or our business,
for our administrative, marketing, promotional, planning, product/service development, quality control and research purposes, or those of our contractors or external service providers,
- To investigate if we have reason to suspect a breach of any of our terms and conditions or any suspected unlawful activity; and/or as required or permitted by any law (including the Privacy Act).
4. WHAT HAPPENS IF WE ARE NOT ABLE TO COLLECT PERSONAL INFORMATION?
If you choose not to provide us with the personal information described within this policy, then:
- We may not be able to provide you with the product or services you have requested, either to the same standard or at all,
- We may not be able to provide you with information about products or services that you may want, including information about discounts, sales or special
- We may not be able to tailor our content, website and communications for your preferences.
5. HOW DO WE COLLECT PERSONAL INFORMATION?
We do this in a variety of ways, including through:
- Your access and use of our website and communications, including your registration details and information relating to your use of the website and the
services, such as the content you access (for example, the products you have viewed, or the search queries you input),
- Your access and use of our Wi-Fi in factory,
- Your conversations or email or interaction, between you and our Customer Service Representatives, whether in factory or on location,
- Your completion of an application for a product purchase or service purchase.
You agree that we may also collect personal information from third parties, including:
- Third party companies such as credit reporting agencies, law enforcement agencies, and other government entities,
- Mailing lists,
- Contractors and business partners.
- To recognise your computer or device and greet you each time you visit our website, without bothering you with a request to register or log-in,
- To keep track of products or services you view, so that we can send you news about those products or services,
- To measure traffic patterns, to determine which areas of our websites have been visited, and to measure transaction patterns in the aggregate,
- To research our users’ habits so that we can improve our online products and services,
- To operate our websites efficiently with a high level of functionality,
- To measure the effectiveness of our marketing initiatives,
- To learn about customer preferences so that we can present customers with web content and advertising that is relevant to them,
- To measure the number of advertising referrals we have received to our websites from other websites,
- To produce data on web traffic and customer web activity through our website.
7. WHAT MAY WE DO WITH YOUR PERSONAL INFORMATION?
We may use the information we collect to help us to provide products and services to you, to verify your identity, and to occasionally notify you about important functionality changes to our website or loyalty club.
We may send you marketing communications and information about products and services that we consider may be of interest to you. These communications may be sent in various forms, including but not limited to, mail, SMS or email, in accordance with applicable marketing laws.
If at any stage you no longer wish to receive these notifications you may opt-out of receiving marketing communications from us by using the opt-out facilities provided (e.g. an unsubscribe link in a promotional email) or email@example.com
If you receive communications from us that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact us.
We do not provide your personal information to other organisations for the purposes of direct marketing unless expressly authorised by you.
Personal Information is information about an identifiable individual, as defined by the Privacy Act 1993.
8. DO WE USE PERSONAL INFORMATION FOR MARKETING?
We use personal information to provide you with information or advice about our existing and new products and services. We also use it to conduct promotions on behalf of Covaflex and selected third parties.
We will not collect usage data or target advertisements based on the following market segments:
- Political opinions,
- Membership of a political association,
- Religious beliefs or affiliations,
- Philosophical beliefs,
- Membership of a trade union,
- Sexual preferences or practices,
- Criminal record,
- Health information.
We will not create categories designed to target children under the age of 18 years (however, this does not prevent us from marketing children’s products to a general audience).
We follow industry “best practice” for the storage of anonymous usage data using reasonable safeguards to protect information held by us.
9. HOW DO WE USE MOBILE?
If you are using one of our mobile applications, and you accept that Covaflex can send you “Push Notifications”, then you are agreeing to accept notifications from Covaflex even when the mobile application is not running. Your “Push Notification” preferences can be configured in the application’s settings.
10. HOW DO WE DISCLOSE PERSONAL INFORMATION?
We may disclose your personal information to our employees, for the operation of our websites or our business, and for the specific purpose of fulfilling requests by you, and to provide products and services to you, and where we are permitted to under the Privacy Act.
Where Covaflex utilises third parties to undertake services, we may provide those third parties with some of your information if it is required to fulfil those services and only to the extent required to fulfil those services. Examples of such third party providers may include:
- Service providers such as web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, photographic analysers, data entryservice providers, electronic network administrators, debt collectors, and professional advisers such as accountants, solicitors, business advisors and consultants,
- Software providers such as customer relationship management, and accounting software
- Existing or potential suppliers, business partners or joint venture entities or partners,
- Sponsors, or promoters of any competition that we conduct or promote via our services,
- Specific third parties authorised by you to receive information held by us
We require any third party to protect your information against unauthorised use or disclosure.
We do not provide your personal information to other organisations for the purposes of direct marketing unless expressly authorised by you.
Beyond the above, we release personal information only when it is permitted under the Privacy Act or required by law for legal compliance and law enforcement (including to government agencies with statutory law enforcement responsibilities, and/or to your Internet Service Provider or network administrator); to facilitate court proceedings; enforce or apply our terms and conditions; or protect the rights, property, or safety of Torpedo7, our users, or others, and where we reasonably believe that disclosure is necessary. Government agencies with statutory roles enabling them to request data from us include but are not restricted to the Police, Inland Revenue and the Ministry of Business, Innovation and Employment.
11. HOW CAN YOU ACCESS OR CORRECT YOUR PERSONAL INFORMATION?
You may request access to any personal information we hold about you at any time by contacting us
Your request will be processed in accordance with the Privacy Act 1993.
If you make an access request, we will ask you to verify your identity. There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, in most circumstances we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment and will not charge for making any amendments. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it. Registered users of our websites can access and update their user details online. We request that you keep your information as current as possible so that we may continue to improve our service to you.
12. HOW CAN YOU COMPLAIN ABOUT A BREACH OF PRIVACY?
We have a formal procedure for investigating and dealing with complaints. Once we receive a complaint in writing we will commence an investigation with the relevant business unit from which the alleged breach stemmed. The investigator will endeavor to determine the nature of the breach and how it occurred.
We may contact you during the process to seek any further clarification if necessary. If a breach is found, we will escalate the matter to management so that the process can be rectified to prevent any further breaches from taking place. We will also contact you to inform you of the outcome of the investigation. We will endeavour to resolve all investigations within a reasonable time.
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
You can write to us at:
158 Walkers Rd
13. WILL YOUR PERSONAL INFORMATION BE DISCLOSED OUTSIDE OF NZ?
We may disclose personal information to external service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
14. WHAT SECURITY MEASURES ARE IN PLACE?
We will take all reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorised access or modification. If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.
For additional information about your relationship with Covaflex, please review our Terms and Conditions.
16. CREDIT CARD SECURITY
We work diligently to protect the security of your personal information, including credit card information.
Your credit card details do not get stored, processed or transmitted through Covaflex website; all transactions are processed through Payment Express. Payment Express is a secure credit card payment service provided by Direct Payment Solutions, and they host and manage the payment page. All transaction sessions are stored and processed in encrypted strings.
Due to the nature of our business being online retail we have a number of security checks in place to protect our website and our customers from such things as credit card theft. Our order system will automatically put orders on hold if it includes such things as high valued items or if a transaction has failed. To release your order you may be asked for Identification and proof of address so your order can be approved. Once checked and approved any proof of identity information collected in relation to your order will be deleted and you will be contacted by email to confirm that this has been done. Due to these checks your delivery may also be delayed