SAFEWORX PRIVACY POLICY
INTRODUCTION
This privacy policy (Policy) applies to all personal information (as defined in the Privacy Act 2020 (New Zealand) (Privacy Act) held by IMPAC Services Limited (New Zealand Company Number: 977706) and CPNZ Limited (New Zealand Company Number: 3479454) (us, we, our, or IMPAC) and Safeworx 2020 Limited (Company Number: 8139770). Safeworx’s business is to supply products and services to our customers to help them comply with their health and safety regulatory obligations (Services).
The Policy outlines our policy and practices for collection of personal information and data, how we use that information, and the options that you have regarding our use of, and your ability to correct, such personal information.
The provisions in this Policy govern only the activities of Safeworx regarding personal information and data. If you disclose your personal information to third parties, or if you are directed to a third party website (whether from our website or by other means) that third party’s privacy notices and practices will apply. We suggest reviewing the third party’s privacy policy before you provide personal information.
In this Policy, where the term “including” is used (or a similar expression is used) that term or expression is deemed to be followed by the words “without limitation”.
2. USING PERSONAL INFORMATION AND DATA
2.1 We collect personal information and data for the following purposes:
2.1.1 to verify a person’s identity
2.1.2 to provide and improve the Services
2.1.3 to market our Services, including by means of direct electronic communication
2.1.4 to undertake credit checks (if we deem it necessary)
2.1.5 to bill and collect money that our customers owe us, including authorising and processing credit card transactions
2.1.6 to respond to communications
2.1.7 for statistical reporting, marketing purposes, and our internal business use
2.1.8 to protect and/or enforce our legal rights and interests
2.1.9 to analyse the traffic of users of the Safeworx website
2.1.10 to provide and improve our website
2.1.11 for any other purpose authorised by the person whose personal information it is, or by the Privacy Act.
3. INFORMATION COLLECTED
3.1 By accessing or using the Services, the website, or by providing information to us, you consent to:
3.1.1 our collection of personal information and data in accordance with this Policy
3.1.2 and the onward transfer, processing, collection, use, disclosure, retention, and storage of personal information and data as described in this Policy.
3.2 We will only collect personal information and data in a manner that is compatible with this Policy.
3.3 We may collect personal information and data from the following sources:
3.3.1 our customer’s health and safety policies and practices (including information about any health and safety incidents, and hazard identification register)
3.3.2 our customer’s contact and payment/bank details (including name, address, phone number, email, bank account number, credit card information, transaction data, and invoicing details)
3.3.3 third party data about our customers in connection with the Services, including information from:
(c) Credit reporting companies
3.3.4 data and analytics on our customer’s use of the Services
3.3.5 traffic, visitor information, and analytics relating to use of the Website and other online aspects of the Services
4. COLLECTING PERSONAL INFORMATION AND DATA
4.1 We collect the personal information and data outlined at clause 3.3 by the following methods:
4.1.1 when a person registers for, and/or uses, the Services
4.1.2 directly from a person including through:
(a) any registration or subscription process (including in person and through web forms or similar methods on the website)
(b) any employment application
(c) information provided to us by email, phone, or in person
4.1.3 using analytics tools on the website and other online components of the Services, including through the use of cookies to monitor a user’s use of the Website
4.1.4 directly from third parties where the person has authorised this
4.1.5 from publicly available resources.
4.2 If we are unable to collect certain personal information or data from you, your use of the Services (and user’s use of our website) may suffer from reduced functionality, and certain features may be disabled.
5.0 HOW DO WE USE YOUR PERSONAL INFORMATION? 5.1 We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to: - Communicate with you; - Screen our orders for potential risk or fraud; and - When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services. 5.2 We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimise our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
6.0 SHARING YOUR PERSONAL INFORMATION 6.1 We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Commerce Vision to power our online store-- you can read more about how Commerce Vision uses your Personal Information here: https://www.commercevision.com.au/privacy-policy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. 6.2 Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
7.0 DO NOT TRACK 7.1 Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
8.0 BEHAVIOURAL ADVERTISING
9.2 We may disclose personal information and data in the following circumstances:
9.2.1 to provide the Services
9.2.2 to provide the Website
9.2.3 to meet the purpose(s) for which it was collected (as set out at clause 3).
9.3 We may disclose personal information:
9.3.1 to another company within the IMPAC group
9.3.2 to any business that supports IMPAC and/or Safeworx to provide and enhance the Services, including website hosting, data analysis and storage, payment processing, information technology and related infrastructure, customer service, service maintenance, e-mail delivery, credit card processing, auditing, and other similar services
9.3.3 to any credit reporting companies
9.3.4 in an aggregated form (such that no personal information is identifiable), for statistical reporting and marketing purposes
9.3.5 for our internal business purposes (including in connection with any audits, professional advice, research, or Service improvements)
9.3.6 to any business that provides IMPAC and/or Safeworx with direct marketing services
9.3.7 In connection with a sale of the IMPAC business, or if IMPAC and/or Safeworx were to merge with or be acquired by another company. If IMPAC and/or Safeworx were to merge with or be acquired by another company, we may share information with them in accordance with our privacy standards. Should such an event occur, we will use our best endeavours to ensure that the new combined entity follows this Policy with respect to personal information
9.3.8 to comply with a request from any regulatory or law enforcement authorities. We will provide requested information in compliance with local laws and regulations, and only in the instance and to the extent where we reasonably believe that we are legally required to do so
9.3.9 to any other person authorised by the person whose personal information and data it is, or by the Privacy Act.
10. PROTECTING PERSONAL INFORMATION AND DATA
10.1 We will take reasonable steps to keep personal information safe from loss, unauthorised activity, or other misuse.
10.2 The Services and the website may be hosted internally or by third party cloud services, and as a result, personal information and data may be processed and stored outside of New Zealand.
10.3 We will take reasonable steps to maintain secure internet connections. Please note that when providing personal information through our website, the transmission may not be completely secure and will depend on your browser and internet settings. We cannot guarantee the security of data transmitted to us through our website and any such transmission is at your own risk.
10.4 If you wish to retain a copy of your personal information and data (or any part of it) please contact us before you finish using the Services, otherwise, upon:
10.4.1 you finishing to use the Services; and
10.4.2 IMPAC and/or Safeworx no longer being required to comply with any legal obligations that require the retention of personal information and data, we will securely delete your personal information.
10.5 Despite clause 10.4 we may retain personal information and data in an aggregated and non- identifying form. 11. ACCESSING AND CORRECTING PERSONAL INFORMATION AND DATA
11.1 You have the right to:
11.1.1 access any of your personal information and data
11.2 request correction of any of your personal information and data, held by us by contacting us using the details given at clause 12.
11.2 Please provide evidence to confirm your identity, and set out the details of your request (including the personal information or correction) when you contact us.
11.3 We will respond to any request in accordance with the Privacy Act (including making available to any readily retrievable personal information, making corrections that are reasonable and that we are reasonably able to, and charging for costs reasonably incurred by us). 12. CONTACT INFORMATION
12.1 If you wish to contact us in relation to this Policy, our privacy standards, or our personal information-handling practices please contact us by email or mail using the details provided below:
Mail: [Re: Privacy Compliance Officer] Safeworx 2020 Limited, 80 Richard Pearse Drive, Unit A, AUK, Mangere 2022, New Zealand
12.2 Note that emails to this address may be distributed to IMPAC and/or Safeworx personnel and tracked for reporting purposes. 13. CHANGES TO THIS POLICY
We may revise and change this policy from time to time, any changes will apply from the date that we upload the revised policy to our website.
Version 1.0 – Last updated August 2024
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