1) Our Privacy Commitment
1.2 We will only use your personal information when it is necessary for us to deliver you a service or perform other necessary business functions and activities.
1.3 We will not use or disclose your personal information for purposes unrelated to our business activities and the services we provide, unless we first obtain your consent.
2) Our Privacy Obligations
(a) Privacy Act 1993 (New Zealand); and
(b) Privacy Act 1988 (Australia).
We are bound by the requirements of these laws, which regulate how we may collect, store, use and disclose your personal information. These laws also specify how individuals may access and correct information held about them.
2.2 “Personal information” means information or an opinion about an identifiable individual (or an individual who is reasonably identifiable), whether true or not, or recorded in a material form or not. By way of example, this type of information could include your name, contact details, age and address.
2.3 In this policy “we”, “us” and “our” refers to The Sticky Handshake Ltd and its related companies and affiliates.
2.5 We will also ensure that we comply with applicable laws regarding unsolicited electronic messages, by including accurate sender information and a functional unsubscribe facility. If you provide us with your personal information, you consent to receiving information from us to promote and market our products and services, or the products and services of others.
3) How and Why Do We Collect and Hold Your Personal Information?
3.1 We have structured our website so that, in general, you can visit our site without identifying yourself or revealing any personal information. You do not have to provide personal information to access our website.
3.2 In some circumstances, we may need to collect your personal information to provide you with services. In some cases, if you do not provide the required personal information, then:
(a) you may not be able to access some of the areas and facilities of our website; or
(b) we may not be able to provide you with our services or otherwise carry out your instructions.
3.4 Our usual practice is to collect personal information directly from you, for instance when you:
(a) establish a The Sticky Handshake account to become a The Sticky Handshake customer
(b) visit or use an The Sticky Handshake website, including any forums, (this may include the address of your Internet service provider, the name of the web page directing you and your clicks and activity on our website);
(c) complete any online form on one of our websites or online payment gateways;
(d) complete an online form on one of our social media channels (for example, Facebook);
(e) complete a survey;
(f) enter a trade promotion or competition;
(g) complete a hard copy form;
(h) provide feedback via phone, e-mail, chat or social media; or
(i) contact us directly by telephone, via mail, e-mail or online.
3.6 We may use services such as Google Analytics, which will issue cookies from their own servers and which will be able to track website visitors throughout relevant websites. We do not control how those cookies are issued, or the data that they store.
3.7 We may use “web beacons” (electronic images also known as pixel tags or clear gifs) to recognise a cookie on your computer when you view or act upon a web page, an advertisement that we have placed on a third party web page, or an email or other electronic communication that we have sent.
3.8 We may also use Local Shared Objects, sometimes referred to as “Flash” cookies. Use of Local Shared Objects can help deter, detect and prevent fraud and can support our Online Services.
3.9 The personal information we collect may include information about people who are employees, directors or principals of yours. We ask you to help us to make sure that these people are aware that our arrangements with you may involve collection of personal information about them.
3.10 If we receive information about you from a third party and it is not information we need in respect of our business activities, we will destroy or de-identify that information (provided it is lawful to do so). If we receive information in error (e.g. via social media) we will act promptly to remove the content.
4) What Kind of Personal Information Do We Collect and Hold?
4.1 Any personal information that you provide via our websites or directly is collected and managed by or for us.
4.3 The types of personal information we may collect includes your:
(b) residential, business and postal address;
(c) email address;
(d) contact telephone numbers;
(e) identification details;
(f) password for online access;
(g) testimonials or opinions;
(h) photos of you;
(i) financial information, such as credit card details;
(j) written or verbal contact with us, including voice recordings of telephone conversations you have had with our employees;
(k) information relating to your access to our website; and
(l) activities, including but not limited to lifestyle and other interests.
4.4 We may also collect personal information directly from job applicants (and their referees) or from recruitment agencies and related service providers. The information we collect may include your name, address contact details, employment and education history, the names of your referees and other relevant information. This information we collect about you will be used for recruitment purposes and may be disclosed to third party service providers who provide recruitment related services to us.
4.5 If you provide us with information about any third party, you must obtain that person’s permission to give us the information and inform them that you have given the information to us.
5) How Do We Use Your Personal Information?
5.1 We use your personal information for a variety of reasons including to:
(a) provide services and products to you;
(b) answer your inquiries and deliver member services to you;
(c) contact you in relation to one of our loyalty, survey or marketing programs;
(d) tell you about other products or services we think may be of interest to you;
(e) enable us to undertake a credit assessment;
(f) maintain and improve member services;
(g) manage your The Sticky Handshake account;
(h) meet our legal obligations;
(i) consider making offers for employment purposes;
(j) manage and resolve any legal, consumer or commercial complaints and issues;
(k) carry out internal functions including training; and
(l) conduct marketing research and analysis.
6) In What Circumstances Might We Disclose Your Personal Information?
6.1 In the course of conducting our business and providing our products and services to you, we may disclose your personal information.
6.2 We only disclose personal information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or activities.
6.3 We never sell email addresses.
6.4 If we engage third party agents or contractors, we will take reasonable steps to ensure that they do not breach privacy requirements in relation to the information, before we share your personal information with them.
7) Who Do We Disclose Your Personal Information To?
7.1 We may disclose your personal information to:
(a) another business or entity associated with The Sticky Handshake Ltd;
(b) to companies that perform services on our behalf such as printers, post suppliers, delivery companies, data entry service providers, trade promotion or gift card administration, account management providers, IT companies that manage and maintain our database and online services, survey companies acting on our behalf and digital marketing agencies (for the purposes of targeting on social media);
(c) professional advisers (such as lawyers or auditors);
(d) payment systems operators and financial institutions;
(e) organisations authorised by us to conduct promotional, research or marketing activities;
(f) upon lawful request from law enforcement agencies or government authorities; and
(g) any persons acting on your behalf including those persons nominated by you, executors, trustees and legal representatives.
7.2 In all circumstances where your personal information is disclosed, we will take reasonable steps to ensure that these third parties undertake to protect your privacy.
8) Direct Marketing
8.1 We are committed to compliance with all laws and requirements relating to the use of your personal information. We will only use or disclose your personal information for direct marketing purposes if you have provided your information for that purpose (and you would expect us to use the information for that purpose), or if you have provided consent for your information to be used in this way (for example, though a catalogue, email or direct mail permission).
8.2 When we contact you it may be by mail, telephone, email, SMS/text message or social media message.
8.3 Where we use or disclose your personal information for the purpose of direct marketing, we will:
(a) allow you to request not to receive direct marketing communications (also known as ‘opting-out’ or ‘unsubscribing’); and
(b) comply with your request to ‘opt-out’ of, or ‘unsubscribe’ from, receiving further communications within a reasonable timeframe.
8.4 By subscribing to our website or The Sticky Handshake services or otherwise providing us with your personal information, you consent to receiving emails which promote our services, or the products and services of others, from time to time.
8.5 From time to time, we may contact you with information about services offered by us and our related entities or our business partners, which we think may be of interest to you.
9) Data quality and Security
9.1 We will take all reasonable steps to ensure that your personal information is stored securely and is protected from misuse and loss and from unauthorised access, modification or disclosure. We use secure servers and industry standard data encryption whenever we are receiving or transferring your personal information online. However, we accept no responsibility for any loss, misuse, unauthorised access or disclosure, alteration or destruction of personal information which you submit to us.
9.2 If you request for us to do so, we will note your member record as ‘deleted’, which means it will not be used for any purpose (such as marketing). However your member name and number may still remain in our database as it will be attached to historical records and transactions.
9.3 Ensure you logout when you have finished visiting our websites especially if you accessed them from a shared computer.
10) Electronic mail
10.1 E-mail and electronic transmission of confidential or privileged documents or advice is a convenient method of delivery. However, internet mail is not secure and any communications or documents transmitted may be interfered with, contain computer viruses or other defects and may not be successfully replicated on other systems. We will not be liable for any copying, recording, reading or interference by others during or after a transmission, for any delay or non-delivery or for any damage caused in connection with a transmission.
10.2 If you have any doubts about the authenticity of any communications or documents purportedly sent by us, please contact us immediately.
11) How you can access or correct your personal information
11.1 You are able to make changes to your personal information via our website or contact centre. You can also request access to the personal information we hold about you at any time (online or over the phone), and we will provide you with that information unless we are prevented by law from giving it to you.
11.2 If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.
11.3 You will not be charged for accessing your information, although we might have to charge the reasonable cost of processing your request, including photocopying, administration and postage. We will advise you of any fee payable before we process your request.
11.4 If you believe that your personal information is not accurate, complete or up to date, please amend via the website, contact us via email to firstname.lastname@example.org or address your request to The Privacy Officer, The Sticky Handshake Ltd, PO Box 54 083, The Marina, Auckland 2014, New Zealand and we will correct this information.
11.5 If you:
(a) have any queries, concerns or complaints about the manner in which your personal information has been collected or handled by us; or
(b) would like to request access to or correction of the personal information we hold about you, please write to:
The Privacy Officer
The Sticky Handshake Ltd
PO Box 54 083