PRIVACY POLICY
Introduction
This Privacy Policy (“this Policy”) applies to “Rand Rescue 2013 Limited” (“we” or “us”). Where we are providing services to you this Policy should be read in conjunction with the agreement under which you engaged us to provide services to you.
We want you to know that we are committed to protecting your privacy and handling your personal information in an open and transparent way.
When handling personal information we will comply with the New Zealand Privacy Act 2020 (as amended from time to time) (the Privacy Act). Where applicable, we will also comply with data protection laws of other jurisdictions, such as the European General Data Protection Regulation (GDPR).
We take our obligations under the Privacy Act and other applicable data protection laws seriously. Therefore, in addition to this Policy, we also:
- Maintain an internal privacy policy; and
- Where appropriate or required by the Privacy Act:
- include terms in our agreements with our clients that describe how we handle personal information during the delivery of our professional services; and
- include terms in our agreements with third parties that describe how we handle the transfer of personal information offshore, ensuring that such third parties are required to protect the information in a way which provides comparable safeguards to the Privacy Act.
How we handle your personal information is governed by the Privacy Act 2020 (Privacy Act) and the Information Privacy Principles under that Act.
We want you to understand what this means for you, including the rights that you have over your personal information. Personal information is information about an identifiable individual (a natural person).
This policy sets out how we will collect, use, disclose and protect your personal information.
This policy does not limit or exclude any of your rights under the Act. If you wish to seek further information on the Act, see www.privacy.org.nz.
When does this Privacy Policy apply?
This Rand Rescue Privacy Policy (Policy) describes how we maintain your privacy when handling your personal information. It applies if:
- you’re one of our clients;
- you use any of our products and services; or
- you visit our website at randrescue.com or any of our affiliated websites (our Sites) or any of our social media channels (our Channels).
By providing personal information to us, you authorise us to collect, hold, use and disclose that information in accordance with, and for the purposes specified in this Policy.
What personal information does Rand Rescue collect?
The types of personal information we collect about you may include:
- your name, postal and street address, email address and telephone number;
- your gender, age, profession, role and place of work;
- records of our communications with you, including any complaints, requests or queries;
- your payment information, such as your credit card or direct debit information and NZBN;
- details of the products and services we have provided to you, or that you’ve enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- when you access our Sites or Channels – your device ID, device type, geo-location information, computer and connection information, statistics on page views, clicks and interactions, traffic to and from our products, services and Sites, and IP address; and
- any other personal information that may be required in order to facilitate your dealings with us.
Where we are provided with personal information by a client, we take reasonable steps to ensure that the client has complied with the relevant obligations under the Privacy Act (and any other applicable data protection laws) in relation to that information. This may include, for example, the client has provided you with notice of the collection (and other matters) and has obtained any necessary consent for us to collect, use and disclose that information.
We also collect personal information (such as contact details and account details) from suppliers, contractors and third party service providers that we engage to help us operate our business.
Information we collect via this Website (Log information, cookies, and web beacons)
We may collect personal contact details from you when you use this Website. For example, if you sign up to receive promotional materials, thought leadership or communications about services provided by us.
To improve your experience when you use this Website and ensure that it is functioning effectively, we also use cookies (small text files stored in a user’s browser) and Web beacons (electronic images that allow this Website to count visitors who have accessed a particular page and to access certain cookies). Additional information on how we use cookies and other tracking technologies and how you can control these can be found in our cookie notice.
Protecting children's privacy
We understand the importance of protecting children's privacy. This Website is not designed for, or intentionally targeted at, children 16 years of age or younger. It is not our policy to intentionally collect or store information about anyone under the age of 16.
How do we collect your personal information
We collect personal information about you from:
- you, when you provide that personal information to us, including via the website and any related service, through any registration or subscription process, through any contact with us (e.g. telephone call or email), or when you buy or use our services and products
- third parties where you have authorised this or the information is publicly available;
- use our Sites or Channels;
- interact with our client support and sales teams;
- complete a form, such as registering for our competitions, training, events and newsletters;
- interact with our authorised partners and certified consultant programs;
- complete our surveys or product testimonials; or
- attend one of our virtual or in-person events.
We may also collect personal information about you:
- from our third-party joint initiative partners;
- that is publicly available, such as from social media;
- through tools that measure and track how you use a product or service or our Sites; and
- from third parties that provide us with marketing leads.
If possible, we will collect personal information from you directly.
How we use your personal information
We will use your personal information:
- to provide services and products to you
- to market our services and products to you, including contacting you electronically (e.g. by text or email for this purpose)
- to improve the services and products that we provide to you
- to respond to communications from you, including a complaint
- to conduct research and statistical analysis (on an anonymised basis)
- to protect and/or enforce our legal rights and interests, including defending any claim
- for any other purpose authorised by you or the Act.
Disclosing your personal information
We will only use or disclose your personal information:
- for the purpose for which it was collected (or a purpose that is directly related to the purpose in connection with which the information was obtained);
- for any other purpose for which you have authorised; and
- otherwise where we are permitted or required to do so by law.
We won’t sell your personal information to third parties without your express consent.
Some of the recipients we may disclose your personal information to include our related companies and third-party service providers who help us to deliver our products and services to you. These third parties provide a variety of services, including client contact, archiving, auditing, professional advisory, banking, data processing, marketing and advertising, data analysis, business intelligence, website, and technology services. Each of these third parties is carefully selected and is only permitted to use your personal information to the extent necessary for them to provide their services to us.
Some of our related companies and third parties to which we disclose personal information may be located overseas, including in Australia and the United Kingdom. These related companies and third parties may not be subject to New Zealand privacy laws. However, we will take such steps as are reasonable in the circumstances to ensure that those organisations are either subject to privacy laws that, overall, provide comparable safeguards to those under the Privacy Act, or are otherwise required to protect the information in a way that, overall, provides comparable safeguards to those under the Privacy Act. Unless you have authorised us to do so, we will not disclose your personal information to an organisation that may not be required to protect your information with comparable safeguards to those under the Privacy Act.
We may also be required to disclose personal information to law enforcement, regulatory or government agencies, or to other third parties:
- To comply with legal or regulatory obligations or requests, such as under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009; or
- Where there is a legal or professional right or duty to disclose.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
Transfer of personal information outside New Zealand
We may store personal information within services provided by offshore cloud service providers.
Some of the recipients of your personal information referenced above may be based in countries or regions outside of New Zealand. Accordingly, any personal information that is collected in connection with our services or your use of this Website may be transferred to countries or regions with privacy laws that are different from New Zealand’s privacy laws. We will ensure that any such transfer of personal information will only be undertaken in compliance with the Privacy Act.
Where we disclose your personal information to other entities in the Rand Rescue Group, or to third party service providers, we will ensure that the relevant third party processes your personal information in accordance with our instructions and in a manner consistent with the Privacy Act (or the GDPR, where applicable).
Blogs, forums, wikis, and other social media
This Website hosts a blog and other social media applications or services that allow you to share content with other users (collectively ‘social media applications’). Importantly, any personal information that you contribute to these social media applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any social media applications will be handled in accordance with this Policy.
Processing and Protecting your personal information
On what basis do we process personal information about you?
Certain data protection laws, such as the European GDPR, require us to have a ‘legal basis’ for processing personal information. Where those laws apply, we may process your personal information for the purposes outlined above because:
(a) You have consented to the processing of your personal information for those purposes;
(b) We have a legitimate interest in processing your personal information, which may be to:
- provide services to you and/or to the entity that has engaged us to provide the services;
- support the management of our client engagements;
- evaluate, develop or improve our services or products; or
- protect our business interests; or
(c) We are subject to legal, regulatory or professional obligations.
(d) The processing is necessary for the establishment, exercise or defence of legal claims.
How do we protect your information?
The security of your personal information is at the heart of our business. We understand that you trust us with very important information, and we’re committed to protecting it.
When you share personal information with us, we usually store it in electronic form. We take reasonable steps to protect the personal information you give us from loss, unauthorised access, use, or disclosure, in line with industry standards. This includes technical and organisational measures, such as arming our web pages with encryption technologies.
Before entering your personal information on our Sites, you can check that the page is encrypted by:
- confirming that the page address in the web browser’s toolbar or status bar begins with https://; or
- checking that the padlock icon in the web browser’s toolbar or status bar is ‘locked’.
We’re also committed to protecting your information offline. Where we hold your business information and personal information, it’s subject to access controls.
While we take reasonable measures to protect your personal information when it’s in our hands, we can’t guarantee the security of the internet as a whole. If you’re using our services, Sites or Channels online, please ensure you’re doing so in a secure environment. In addition, if you use email to send and receive your personal information, please be aware that the information may be less secure in transit.
Accessing and correcting your personal information
You have the right to access the readily retrievable personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.
In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, 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.
Depending on the jurisdiction in which you are located, you may also have the right to:
- Ask that we delete personal information that we hold about you, or restrict the way in which we use your personal information;
- Withdraw consent to our processing of your personal information (to the extent our processing is based on your consent);
- Obtain and/or move your personal information to another service provider; and/or
- Object to our processing of your personal information.
If you want to exercise either of the above rights, email us at henrico.kotze@randgroup.biz. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).
We may charge you our reasonable costs of providing you with copies of your personal information or correcting that information.
Internet use
While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.
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 suggest you review that site’s privacy policy before you provide personal information.
Changes to this policy
We may change this policy by uploading a revised policy onto the website. The change will apply from the date that we upload the revised policy.
Web designer/host notice
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The Web Designer/Host remains detached from any customer information sent to Rand Rescue through online or email channels and is not accountable for overseeing the gathering, handling, safeguarding, dissemination, and processing of Rand Rescue's data. Furthermore, the Web Designer/Host is excluded from accessing or evaluating the compliance or regulatory frameworks the responsible entity adheres to.