This Policy was last updated on 10 November 2017.
The Joolca New Zealand Limited Partnership (number 2668751) (“we”, “our” or “us”) is committed to protecting your personal information and your credit related personal information (“credit information”). This Policy sets out our policies relating to how your personal information and credit information is collected, used, stored and disclosed. These policies are based on the obligations set out in the Privacy Act 1993 (“Privacy Act”) (including New Zealand Privacy Principles (“NZPPs”) and the Credit Reporting Privacy Code 2004.
We are bound by the requirements of those laws, which regulate how we may collect, store, use and disclose your personal information and credit information. Those laws also specify how individuals may access and correct information held about them. By supplying us with your personal information or credit information or using our products or services, you are agreeing to be bound by this Policy.
Amendments or Updates: Any amendments to this Policy will be notified to you by posting an updated version on our website. Your use of our website or services following any updates constitutes acceptance of this Policy as amended. We recommend you regularly review the Policy when you visit our website. If you do not agree with any aspect of the updated Policy, you must promptly notify us and cease using our products or services.
Collection of personal information
We collect information that you provide. The personal information we may collect and store includes:
- contact information such as your name and address, telephone numbers and email address;
- financial information, including bank account details and credit card details; and
- information about your business.
In addition, we may collect store the following credit information:
- identification information – such as your name, date of birth, current or previous address or driver’s licence number;
- type and amount of credit sought;
- trade references – such as the name of the relevant entity, contact name, telephone number, fax number, email or years trading with you; and
- publicly available information about an individual’s creditworthiness.
- your server address;
- your top level domain name (for example, .com, .gov, .nz etc);
- the date and time of your visit to the site;
- the pages you accessed;
- the previous site you have visited; and
- the type of browser you are using.
Means of collection of personal information and credit information
Your personal information and credit information may be collected in a number of ways, including:
- directly by our staff when you seek, or enquire about, our goods or services; or
- when you use our website or complete a form on our website.
In some circumstances, where it is unreasonable or impracticable to collect credit information or personal information from you, we may collect credit information or personal information about you from a third party source. For example, we may collect credit information or personal information from a publicly maintained record.
In addition to the methods above, we may collect credit information from other credit providers, subject to any restrictions at law.
You need not provide all the credit information or personal information requested by us, but this may prevent us from providing some or all of our goods or services to you.
Use, disclosure & purpose
We collect, use, store and disclose your personal information and credit information for the following purposes:
- as a necessary part of providing our products or services to you;
- to promote and market our products or services to you or provide you with information that we believe may be of interest to you (unless as directed otherwise);
- to personalise and customise your experiences with our website;
- to help us research the needs of our customers and to market our products with a better understanding of your needs and the needs of customers generally;
- to allow us to provide advertising material to you regarding us, our dealers and customers, and other business partners (unless as directed otherwise); and
- other purposes related to any of the above.
By using our products and services, you consent to your personal information and credit information being collected, stored, used and disclosed in this way and for any other use you authorise.
We will only use your credit information or personal information for the purposes for which it was collected (“primary purposes”) or a purpose related to the primary purpose, if this use would be reasonably expected by you, or otherwise, with your consent.
- third parties that provide goods and services to us or through us;
- third parties, such as marketing and digital agencies, who may send to you our e-newsletters on our behalf; and
- our website host or software application providers.
We do not intentionally disclose your personal information to overseas recipients. However, our software application providers, including Xero, may hold personal information on servers located outside Australia. Further information on Xero’s handling of personal information is available at www.xero.com/au/about/terms/privacy.
Quality, access to & correction of information
It is your responsibility to ensure that the personal information you provide is accurate, complete and up-to-date.
You are entitled to have access to and seek correction of any personal information or credit information that we may hold about you that is readily retrievable. We require that requests for access to or to update or correct your personal information or credit information to be in writing outlining the details of your request. Such requests should be addressed to the Privacy Officer via the details provided in this Policy.
We will take appropriate steps to verify your identity (or verify that you act as an authorised agent of the individual concerned) before granting a request to access your personal information or credit information.
We will respond to your request for access to your personal information or credit information within a reasonable time after you make the request and if access is granted, access will be provided within 30 days from your request. We will, on request, provide you with access to your personal information or update or correct your personal information or credit information, unless we are lawfully excluded from granting your request, including if:
- giving access would be unlawful;
- we are required or authorised by law or a court/tribunal order to deny access; or
- giving access is likely to prejudice one or more enforcement related activities conducted by an enforcement body.
Where your request for access is accepted, we will provide you with access to your personal information or credit information in a manner, as requested by you, providing it is reasonable to do so.
Your request for correction will be dealt with within 20 days, or such longer period as agreed by you. If we deny your request, we will provide you with a written notice detailing reasons for the refusal and the process for making a complaint about the refusal to grant your request.
We will accept your request for correction of your credit information where we are satisfied that it is inaccurate, out-of-date, incomplete, irrelevant or misleading.
Upon accepting a request for correction of your personal information, we will take all steps that are reasonable in the circumstances, having regard to the purpose for which your information is held, to correct your personal information.
If your request for correction of credit information is accepted we will provide written notice of this correction to any entity to which we have disclosed this information previously, to the extent that this is reasonably practicable. If your request for correction of your credit information is not made, we will tell you why.
Storage and Security
Your personal information and credit information will be stored as physical files in a secured area, on our electronic data base system and on computers with appropriate back up and security systems. Any personal information or credit information which is collected via our website, or which is held on our computer systems, is protected by safeguards including physical, technical (including firewalls and SSL encryption) and procedural methods.
We take reasonable steps to hold information securely in electronic or physical form. We are committed to keeping secure the data you provide to us and we will take all reasonable precautions to protect your personally identifiable information from loss, misuse, interference, unauthorised access, disclosure or alteration.
We aim to achieve this through:
- imposing confidentiality requirements on our employees;
- implementing policies in relation to document storage security;
- implementing security measures to govern access to our systems;
- only providing access to personal information once proper identification has been given;
- controlling access to our premises; and
- implementing website protection measures.
Dealing with us anonymously
Where lawful and practicable to do so, you can deal with us anonymously or using a pseudonym. You can deal with us anonymously or using a pseudonym when making a general enquiry about the goods and services that we can offer to you including via telephone or our website.
At the time you purchase our goods, it is no longer practicable for you to deal with us anonymously or using a pseudonym.
Credit Information Notifiable Matters
In accordance with our obligations under the Privacy Act, we set out the following notifiable matters in relation to any of your personal information or credit information disclosed by us to a credit reporting body for the purposes of undertaking a credit check in relation to credit provided to you:
·In connection with the provision of credit, we may disclose your personal information and credit information to the following credit reporting bodies for the purposes of undertaking a credit check in relation to an application made by you.
You may contact Equifax using the details set out below:
- via Equifax’s website at email@example.com, firstname.lastname@example.org; or
- phone: 0800 653 309.
Dun & Bradstreet
You may contact Dun & Bradstreet using the details set out below:
Phone: 0800733 707
You may contact Centrix using the details set out below:
Phone: +64 9 9669706
- Equifax, Dun & Bradstreet or Centrix may include any of your personal information or credit information, disclosed to them by us, in reports provided to other credit providers to assist other credit providers to assess your credit worthiness.
- Our policy about the management of personal information and credit information is set out in this Policy.
- You have the right to make a request to Equifax, Dun & Bradstreet and Centrix not to use or disclose your credit information:
- for the purposes of pre-screening of direct marketing by a credit provider; or
- if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud.
- If you fail to meet any of your payment obligations under the terms of the credit that we provide to you, or if you commit a serious credit infringement, we may be entitled to disclose this to Equifax, Dun & Bradstreet or Centrix.
If you believe that we have breached a term of this Policy or the Privacy Act you may submit a written complaint to our Privacy Officer. The written complaint can be emailed or posted to us using the contact details set out below. You must include contact details for us to contact you regarding your complaint.
Our Privacy Officer will consider your complaint and respond as soon as reasonably possible, but not more than 30 days from receiving the complaint.
If you are unsatisfied with the outcome of your complaint you may refer your complaint to the Privacy Commissioner to be resolved.
If you wish to:
- gain access to your personal information or credit information;
- make a complaint about a breach of your privacy;
- contact us with a query about how your personal information or credit information is being collected, used, stored or disclosed;
- contact us regarding any other matter concerning this Policy,
you can speak directly with our staff who will do their best to try to resolve your issue as simply as possible. Alternatively, you can write to us or send us an email so that our Privacy Officer can consider the matter. We will respond to you as soon as reasonably possible.
If you do not wish to receive direct marketing from us, please contact our Privacy Officer via the details below. Our contact details are as follows:
Phone: 1300 669 500
Privacy Officer contact: Maciek Slodyczka
Postal address: 45 Metrolink Circuit, Campbellfield Victoria 3061
For more information on privacy see the Privacy Commissioner's website at: https://www.privacy.org.nz/.