Privacy Policy

EFFECTIVE DATE: MARCH 16, 2020

This policy sets out how Carlyon (we) collects, uses and discloses personal information. Personal information is information about an identifiable individual (i.e. a natural person) (you). We comply with the applicable privacy laws, including the New Zealand Privacy Act 2020 (Act). You can find out further information about the Act at www.privacy.org.nz.

PERSONAL INFORMATION
We collect personal information about you in order to deliver our services to you.  We collect this directly from you when you access our services or engage with us through our websites and surveys.

 If you access any of our services (including supporting our campaigns, responding to surveys, contacting us from our website, signing up for our newsletters), we will collect some or all of the following personal information:

• your name
• contact information including contact number(s) and email address
• a record of any queries you have made
• website activity
• any correspondence with our staff

We may also collect:

• your date of birth and/or age
• your gender
• your location (e.g. address, GPS location, latitude/longitude, coarse or fine etc)
• other contact details (e.g. postal address, email address, phone number, Twitter handles)
• about your interactions with us
• your computer or network (e.g. browser identifiers/fingerprints, IP address, network information, International Mobile Equipment Identity (IMEI) number)
• any other information you choose to provide us

Collectively, the above is known as your “personal information“.

HOW WE COLLECT PERSONAL INFORMATION
Wherever possible, we collect personal information directly from you such as  you provide that personal information to us, including via:

• our website
• an electronic form or application
• a registration or subscription process
• our contact with you (e.g. in person or by phone, zoom, email or mail)
• any other means authorised or requested by you

 We may also collect your personal information from:

• publicly available information
• third parties, where you have authorised or requested us to do so

 WHY WE COLLECT YOUR PERSONAL INFORMATION
We collect your personal information when it is necessary for a purpose connected with a function or activity that we carry out, including to:

• verify your identity
• provide products and services
• market our products and services
• improve our products and services
• improve the way we provide our products and service
• inform you of our services, promotions, competitions and other marketing activities
• reward you for being a loyal customer
• bill and get paid by you (e.g. authorising and processing credit card transactions)
• communicate with you
• carry out research and statistical analysis (on an anonymous basis)
• protect and/or enforce our rights and interests
• when you apply to be employed or contracted by us, for recruitment, employment, and contracting purpose
• fulfill any other purpose authorised or requested by you

STORAGE, ACCESS AND CORRECTION
We is dedicated to keeping personal information secure. This includes physical security, computer, and network security, communications security, and personnel security. In order for Carlyon to provide services to you, personal information is held by Carlyon-associated companies in accordance with this policy.

You have rights of access to and correction of personal information that Carlyon holds. You may correct or change the information collected at any time and as often as necessary. To access, correct or change your personal information contact Carlyon’s Privacy Officer by emailing service@carlyon.co.nz

DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information to: 

• Hubspot which we use as our CRM.
• Autopilot for our marketing automation 
• [a credit reference agency for the purpose of conducting a credit check on you]
• a person who can require us to supply your personal information (e.g. a regulatory or government authority)
• any other person authorised by the Act or another law (e.g. a law enforcement agency)
• any other person authorised or requested by you

We do not share your personal information with any overseas providers which are not subject to the Act. If we were to do so, we would obtain prior authorisation from you before we disclose it to any such third parties.

We do not sell, rent, or otherwise make available any personal information to any third party.

For the purpose of providing services to you, personal information may, as required, be transferred to or handled by our associated companies and/or other organisations which provide services to us, such as research, mailing houses, promotion, and advertising agencies. However, we do share your personal information with trusted third parties that work on our behalf to deliver our services to you.

PROTECTING YOUR PERSONAL INFORMATION
We will take reasonable steps to ensure your personal information is securely stored and safe from loss, unauthorised activity, or misuse. However, please be aware that the internet is not a secure environment. If you send us any information over the internet (in whatever way or format), you send it at your own risk.

We store your personal information we collect from you in accordance with our obligations under the Act and take reasonable steps to ensure the security of your personal information. We use trusted third-party providers to store and process our data and ensure that our cloud-based platforms meet New Zealand privacy requirements.  Such providers may be based in New Zealand or overseas.  The reasonable steps we take include physical security, computer, and network security, communications security, and personnel security. In order for us to provide services to you, personal information may also be held by our associated companies in accordance with this policy.

INTERNET OF USE
If you post your personal information on our website through message boards, chat rooms, or other public forums (if any), you acknowledge and agree that the information you post is publicly available.

If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal information.  We strongly suggest you review that site’s privacy policy before you provide personal information.

IF INFORMATION IS NOT PROVIDED
If you do not provide all or any part of the personal information we request, you may be unable to set up an account with us and/or we may be unable to provide (or continue to provide) products and services to you.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You can ask for the personal information we hold about you (if it is readily retrievably by us). Before we provide any information to you, we will need evidence that you are the individual to whom the personal information relates. 

If your personal information is wrong, you can ask for it to be corrected. If we consider that the correction is reasonable (and we are reasonably able to make the correction), we will make the correction. If we do not make the correction, we will take reasonable steps to note the personal information that you requested the correction.

COOKIES
We use cookies, web beacons, and other digital tracking tools on our websites (cookies).  Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. They are small text files that are placed on your computer by the websites that you visit. 

Collecting these helps us understand how visitors engage with our website and services. These technologies allow us to: 

• Improve our website (for example, identify and promote popular content); and
• Provide you with more targeted information where appropriate.
  We also use third-party cookies and other technologies for marketing and to gather website analytics. This includes: 
• Remarketing and emails: we use third-party cookies – such as Google Analytics and AdWords cookies – to keep track of the content you’re interested in and remarket it to you when you leave our site (as a result, you may see ads from Consumer NZ when you visit other websites).
• Impression reporting: we use web beacons to estimate the number of users that have viewed and clicked on our advertisements (as a result, we’re able to gauge the success of a campaign).
• Demographics and interest reporting: we use cookies and web beacons to get an overview of our readership broken down by age, gender, and interests such as site maintenance and fuel (as a result, we can provide you with relevant information, services, and features and also gauge the popularity of our content).

You can opt-out of Google Analytics without affecting how you visit our site, visit this page

When we collect cookies from third parties, this information is collected in aggregated form. That means that we do not collect any personal information from third parties about you. However, we may collect aggregated information and information about household electricity consumption and combine that information with personal information we hold about you.

If you do not agree to the use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site.

YOUR CONSENT
By providing information to us (in whatever way or format), you consent to us collecting, using, and disclosing that information in accordance with this policy and the Act.

CHANGES TO PRIVACY POLICY/DISCLAIMER
We may change this policy by uploading a revised policy to our website. The revised policy will apply from the date it is available on our website. Your continued use of our website is your acceptance of the updated privacy policy.

CONTACTING US
We are committed to dealing quickly and appropriately with any privacy matters. To submit a request, or otherwise contact us in connection with this policy, please contact us by email at service@carlyon.co.nz or by phone at 0800 243 864 for the attention of our privacy officer.

If we cannot adequately address your privacy concerns, you have the right to complain to the Office of the Privacy Commissioner. For more information on privacy, see the Privacy Commissioner’s website.